ML18022A777

Responds to NRC 900131 Ltr Re Violation B Noted in Insp Rept 50-400/89-34.Corrective Actions:Applicable Emergency Diesel Generator Surveillance Test Procedures Will Be Modified to Specify Acceptance Criteria Re Frequency & Voltage

ML18022A777
Person / Time
Site:	Harris
Issue date:	02/26/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-702 HO-900042-(O), NUDOCS 9003080139
Download: ML18022A777 (7)

Text

ACCELERATED DISHUBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

SSION NBR:9003080139 DOC.DATE:

~ 90/02/26 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400

~

AUTH. NAME AUTHOR AFFILIATION RICHEY,R.B. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900131 50-400/89-34.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IEOID TITLE: General (50 COPIES RECEIVED:LTR ( ENCL Dkt)-Insp Rept/Notice of Violation Response L SIZE:

5 NOTES:Application for permit renewal filed. 05000400 ]

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ' ENCL PD2-1 PD 1 1 BECKER,D 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1

NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 2 NRR/DRI S/DIR 1 1 NRR/DST/DIR 8E2 1 1 I

NRR/PMAS/ LRB1 2 1 1

1 1 EG FILE 0 1

1 1

1 OGC/HDS1 RES MORISSEAU,D 1 1 01 1 1 EXTERNAL: LPDR 1 '1 NRC PDR 1 1 NSIC 1 1 R

D NQIZ TO ALL "RIDS" RECIPIENIS:

PLEASE HELP US TO REDUCE WASIZI CONTACf THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELMINATEYOUR NAME FROM DISHUBUTION TAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

Carolina Power & Ught Company P. O. Box t65 ~ New Hill, N. C. 27562 R. B. RtCHEY tte FEB 2 6 1990 Harrla Nvctear Project Letter'Number.'0-900042 (0)

Document Control Desk NRC-702 United States Nuclear Regulatory Commission Washington, DC 20555 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 "B" 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, 8~iÃd, Harris Nuclear Project MGW:dgr Enclosure cc: Mr. R. A. Becker (NRC)

Mr. S. D. Ebneter (NRC RII)

Mr. J. E. Tedrow (NRC SHNPP) 9003080139 3 900226 PDR ADOCK 05000400 Q PDC MEM/HO-9000420/1/OS1

8 ATTACHMENT TO CP&L LETTER OF RESPONSE TO NRC I ~ E ~ REPORT RI I 50 400/89 34 ~ VIOLATION B Re orted Violation.'echnical Specification 3.8.1.1 action "b" requires in part, that the A.C. off site power sources be demonstrated operable when an emergency diesel generator is inoperable, by performing surveillance requirement 4.8.1.1.l.a within one hour and at least once per eight hours thereafter.

Surveillance requirement 4.8.1.l.l.a specifies that the A.C., off site power sources'e determined operable by verifying correct breaker alignment and power availability.

Contrary to the above, while the "B" emergency diesel generator was inoperable from approximately 9:45 a.m. on January 1, 1990, until 2:35 p.m. on January 2, 1990, the A.C. off site power sources were not determined to be operable by verifying correct breaker alignment and power availability at least once per eight hours.

Denial or Admission and Reason for the Violation:

The violation is correct as stated.

The violation occurred because the "B" Emergency Diesel Generator (EDG) was incorrectly declared operable on January,l, 1990, and the surveillance of off site power circuits required by the applicable action statement was suspended.

The EDG was initially declared inoperable based on the observation that while the, "B" EDG speed did'roduce a generator frequency greater than 58.2 Hertz (the minimum acceptable value) within 10 seconds after the start signal, the frequency did not immediately stabilize within a speed equivalent to 60 + 1.2 Hertz. The surveillance procedure called for measurement of the time to achieve the minimum values stated in the Technical Specifications (58.2 Hertz and 6210 Volts). The results of the test were reviewed with the applicable system engineer, and management in Regulatory Compliance and Operations. The conclusion that was reached was that the surveillance was satisfied by achieving the minimum values within the 10 second time limit.

Consequently the "B" EDG was declared operable at 09:45 on January 1, 1990.

As a direct consequence the "A" EDG, was subsequently taken out of service to perform a post run air roll later on January 1. Technical Specifications specifically exempt the implementation of this air roll when the opposite EDG is inoperable. After review of the initial test results with the NRC Senior Resident Inspector on January 2, the "B" EDG was declared inoperable retroactive to December 31, 1989. This resulted in the condition where the plant inadvertently entered the Technical Specification where both EDG's were inoperable simultaneously. The applicable action statement allows two hours for the restoration of at least one EDG. Review of applicable logs indicates that this time limit was satisfied.

MEM/HO-9000420/2/OS1.

Corrective Ste s Taken and Results Achieved:

Subsequent to a meeting with the Resident I nspector to discuss this issue, the action statement for the inoperable EDG was reentered. The LCO action time start was taken to be the time of the conclusion of the test on December 31, 1989. Adjustments were made to the EDG governor and the EDG was successfully retested on January 2, 1990. The required off site power verifications were completed between the time that the LCO action was reapplied and the time the EDG was declared operable.

Corrective Ste s Taken to Avoid Further Violations:

The applicable EDG surveillance test procedures will be modified to specify acceptance criteria that verify that the frequency and voltage at 10 seconds will be recorded and compared with the applicable acceptance criteria.

Date When Full Com liance Will Be Achieved:

The applicable EDG surveillance test procedure's will be modified by March 30, 1990.

MEM/HO-9000420/3/OS1