ML18011A868

Forwards Response to NRC 950302 Ltr Re Violations Noted in Insp Rept 50-400/95-02.C/A:temp Mod to Bypass Thermal Overloads Installed on Six AFW MOVs Until Enhanced Testing Could Be Performed When Allowed

ML18011A868
Person / Time
Site:	Harris
Issue date:	03/30/1995
From:	ROBINSON W R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-95-035, HNP-95-35, NUDOCS 9504040302
Download: ML18011A868 (5)

See also: IR 05000400/1995002

Text

P RID RI'YY 1 (ACCELERATED

RIDS PROCESSING)

REGULATORY

INFORMATXON

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:9504040302

DOC.DATE: 95/03/30 NOTARXZED:

NO FACIL:50-400

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

ROBINSON,W.R.

Carolina Power&Light Co..RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Forwards response to NRC 950302 ltr re violations

noted in insp rept 50-400/95-02.C/A:temp

mod to bypass thermal overloads installed on six AFW MOVs until enhanced testing could be performed when allowed.DISTRIBUTXON

CODE: IE01D COPIES RECEIVED:LTR

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

of Violation Response DOCKET 05000400 P NOTES:Application

for permit renewal filed.05000400 I RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL ACRS AEOD/SPD/RAB

AEOD/TTC.+FILE CENT~ER 02 NRR/DORS/OEAB

NU DOCS-ABSTRACT

OGC/HDS2 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1.1 1 1 1, 1 1 1 1 1 1 1 1 1 1 1 RECXPIENT ID CODE/NAME LE,N AE5D/DEIB AEOD/SPD/RRAB

DEDRO NRR/DISP/PIPB

NRR/DRCH/HHFB

OE DIR RGN2 FILE Ol NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 T Y G NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT.504-2083)TO ELI!i!INATE YOUR NA!iIE FROM DISTRIBUTION

LISTS FOR DOCUMEVTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED:.LTTR 20 ENCL 20

Carolina Power&Light Company PO Box 165 New Hill NC 27562 William R.Robinson Vice President Harris Nuclear Plant MA,R 3 0'l99S, File: HO-950510 Serial: HNP-95-035

10 CFR 2.201 United States Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400/LICENSE

NO.NPF-63, REPLY TO A NOTICE OF VIOLATION (NRC INSPECTION

REPORT NO.50-400/95-02, MOTOR OPERATED VALVE THERMAL OVERLOAD BYPASS TESTING)Gentlemen:

Attached is Carolina Power 8c Light Company's reply to the Notice of Violation described in Enclosure 1 of your letter dated March 2, 1995.Questions regarding this matter may be referred to Mr.D.C.McCarthy at (919)362-2100.Sincerely, W.R.Robinson MGW Attachment

c: Mr.S.D.Ebneter (NRC-RII)Mr.S.A.Elrod (NRC-SHNPP)

Mr.N.B.Le (NRR)OQAt Qo.9504040302

950330 PDR ADOCK 05000400 9 PDR State Road 113'ewHill

NC Tel 919362-2502

Fax 919362-2095

Attachment

to HNP-95-035

Page 1 of 3 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50-400/95-02

Re orted Violation:

Technical Specification 4.8.4.2 requires that the thermal overload protection

for each valve, specified in the Technical Specification

Equipment List Program, plant procedure PLP-106, requiring bypass protection, shall be verified to be bypassed only under accident conditions

by an OPERABLE integral bypass device by the performance

of a TRIP ACTUATION DEVICE OPERATIONAL

TEST of the bypass circuitry at least once per 18 months for those thermal overloads which are normally in force during plant, operation and are bypassed only under accident conditions.

Contrary to the above, on January 19, 1995;it was determined

that the thermal overload protection, for six auxiliary feedwater motor operated valves, was inadequately

tested.The test used did not isolate all electrical

flow paths other than the bypass relay contacts, and therefore did not conclusively

show the bypass relay to be operable.Specifically, the test did not interrupt the normal electrical

flow path through the thermal overload contacts.This is a Severity Level IV violation (Supplement

I).Denial or Admission:

The violation is admitted.Reason for the Violation:

On January 19, 1995, a review and evaluation

of plant operational

electrical, surveillance

test procedures

revealed that the proper operation of the thermal overload (TOL)bypass function for Auxiliary Feedwater (AFW)System valves 1AF-55, 1AF-74, 1AF-93, 1AF-137, 1AF-143 and 1AF-149 (AFW pump discharge isolation valves), as well as Main Steam (MS)System Valve 1MS-70 (AFW turbine driven pump steam supply valve), had not been adequately

tested.The testing methodology

utilized to verify the TOL bypass function included confirmation

that the applicable

relay actuated and rolled, that contacts'on that relay made up, and that the motor operated valves (MOVs)stroked.This proved that the relay functioned

properly and that certain circuit paths were operable.However, due to the existence of parallel circuit paths during this testing alignment, there was not conclusive

proof that all bypass contacts and associated

circuits were functioning

as required.The inadequate

thermal overload (TOL)testing was caused by deficiencies

which existed in the surveillance

testing methodology

established

during initial plant startup.Reference:

Licensee Event Report 95-001-00 submitted to the Commission

on February 16, 1995.

Attachment

to HNP-95-035

Page 2 of 3 Corrective

Ste s Taken and Results Achieved: On January 19, 1995, a temporary modification (ESR-95-00039

&ESR-95-00058)

to bypass the thermal overloads was installed on the six AFW MOVs until enhanced testing could be performed when plant conditions

allow (i.e., plant shutdown.)

Test procedure OST-1812, Auxiliary Feedwater Isolation:

ESF Response Time 18 Month Interval Modes 4-6, was revised on February 20, 1995, to adequately

verify the operability

of the TOL bypass function for the six AFW MOVs.This testing is currently planned for RFO¹6 scheduled to begin September 2, 1995.Test procedure OST-1044, ESFAS Train A Slave Relay Test Quarterly Interval Modes 1-4, for 1MS-70 was revised (TC-00001)

and successfully

performed on January 19, 1995, to verify the operability

of it's TOL bypass function.3 On January 25, 1995, during additional

investigation, three examples of inadequate

TOL bypass function testing for Control Room Emergency Ventilation

Valves (1CZ-22, 1CZ-24, 1CZ-26)were identified.

This investigation

revealed that during a revision to the Engineered

Safety Feature Train"B" Response Time Test Procedure (OST-1826), that was completed prior to the.most recent refueling outage (RFO¹5), the requirement

to place the TOL test switch to"test" was inadvertently

deleted.This condition also allowed for the existence of parallel circuit paths during the test alignment and the subsequent

inconclusive

proof that all bypass contacts and associated

circuits were functioning

as required.Immediate corrective

actions for this condition included completing

a procedure revision to the Engineered

Safety Feature Train"B" Slave Relay Test (OST-1084)

and successfully

performing

the procedure to verify TOL bypass~operability.

These actions were completed on January 25, 1995.Procedure OST-1826 will be revised to properly verify the operability

of TOL bypass functions by October 6, 1995.Corrective

Ste s Taken to Prevent Further Violations:

A review was performed of PLP-106 and the applicable

surveillance

test procedures

to ensure that TOL bypass functions are properly identified

and tested as required.No additional

discrepancies

were found.An additional

review will be performed of surveillance

test procedures

to identify similar applications

of the previously

accepted testing methodology.

This will ensure that component testing explicitly

required by Technical Specifications, properly verifies each aspect of the required component function.This review will be completed by June 30, 1995.It is noteworthy

to acknowledge

that the AFW and MS valve actuators have been designed, setup and satisfactorily

tested in accordance

with the requirements

of the Generic Letter 89-10, Motor Operated Valve Program.By satisfying

the GL 89-10 requirements, the AFW and MS valve actuators have demonstrated

their ability to close during design accident conditions, even without the thermal overload functions bypassed.Furthermore, our operating and maintenance

history with these particular

relays (which accomplish

valve actuation and bypass function)has been such that no relay failures have been experienced

which would have led to the described scenario.This, in conjunction

~~Attachment

to HNP-95-035

Page 3 of 3 Corrective

Ste s Taken to Prevent Further Violations: (continued)

with the previously

performed surveillance

testing, provides confidence

that the valves would have shut in the event of a design basis accident.E For the Control Room Emergency Ventilation

Valves (1CZ-22, 1CZ-24 and 1CZ-26)that were not tested as required during RFO¹5, proper operation of the TOL bypass function was demonstrated

by satisfactory

testing on January 25, 1995.These MOV TOL bypass functions had also been previously

verified during successful

ESF B Train Response Time Testing during each of the preceding refueling outages.Based on this, there is a high level of confidence

that they would have performed their design function had an accident occurred which required a Control Room Ventilation

Isolation Signal.Date When Full Com liance Will Be Achieved: Full compliance

will be achieved by October 6, 1995 (end of RFO¹6), with the completion

of the corrective

steps stated above.