ML18010A369

Responds to NRC Re Violations Noted in Insp Rept 50-400/91-15.Corrective Actions:Procedure on Temporary Bypass,Jumper & Wire Removal Updated to State Use of Jumpers During Troubleshooting Is Excluded from Scope of AP-024

ML18010A369
Person / Time
Site:	Harris
Issue date:	08/16/1991
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-91-212, NUDOCS 9108260104
Download: ML18010A369 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9108260104 DOC.DATE: 91/08/16 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION WATSON,R.A.

Carolina Power 6 Light Co.

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

DOCKET 05000400 R

SUBJECT:

Responds to NRC 910723 ltr re violations noted in insp rept 50-400/91-15.Corrective actions:Procedure on Temporary Bypass, Jumper

& Wire removal updated to state use of gumpers during troubleshooting is excluded from scope of AP-024.

DISTRIBUTION CODE:

IE14D COPIES RECEIVED:LTR

]

ENCL SIZE:

TITLE: Enforcement Action Non-2.790-Licensee

Response

NOTES:Application for permit renewal filed.

05000400 RECIPIENT ID CODE/NAME PD2-1 LA MOZAFARI,B.

INTERNAL: AEOD/DOA DEDRO NRR/PMAS/ILRB12 OE DIE

~5EG~Z-.LE'2 RGN2/DRSS/EPRPB EXTERNAL: NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 RECIP1ENT ID CODE/NAME PD2-1 PD AEOD/DSP/TPAB NRR/DOEA/OEAB11 NUDOCS-ABSTRACT OE FILE 01 RGN2 FILE 03 NSIC COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 D

D D

NOTE TO ALL"RIDS" RECIPIENTS:

D D

PLEASE HELP US TO RFDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl.-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED:

LTTR 16 ENCL 16

0

COAL Carolina Power & Ltgkt Company P. O. Box 1551

~ Raleigh. N. C. 27602 R. A. WATSON Senicr Vice Prestrtent Nuclear Generation SERIAL:

NLS-91-212 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 NOTICE OF VIOLATION (EA 91-076)

I Gentlemen:

On July 23,

1991, the Nuclear Regulatory Commission issued a Notice of Violation (EA 91-076) for issues at the Shearon Harris Nuclear Power Plant.

Details of the NRC inspection are provided in Inspection Report No.. 50-400/91-15 dated July 23, 1991.

Carolina Power

& Light Company hereby responds to the Notice of Violation.

The enclosure to this letter provides CP&L's reply to the Notice of Violation in accordance with the provisions of 10 CFR 2.201.

Also enclosed is a check payable to the Treasurer of the United States in the amount of Fifty Thousand Dollars

($50,000.00).

Please refer any questions regarding this submittal to Mr. S.

D. Floyd at (919) 546-6901.

RAW/MGW Enclosures Yours very truly, Xc+C<Z /~B ->>;-

R. A. Watson cc:

Mr. S.

D. Ebneter Ms.

B. L. Mozafari Mr. J.

E. Tedrow gee(( ~9-9 %8'<9 P<R 5diaoc, oo P ~ g Xv commission expires:

g/pg/if'10S260104 9i08fr'DR ADOCK 0=000400 0

PDR R. A. Watson, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are

officers, employees, contractors, and agents of Carolina Power

& Light Company.

s

~

sI I

Notary (Seal)

ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400 OPERATING LICENSE NO. NPF-63 REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY VIOLATION A:

Technical Specification 3.3.1 requires that the Reactor Trip System shall have a minimum of two automatic trip instrumentation channels operable when the Reactor Trip System breakers are closed and the Control Rod Drive System is capable of rod withdrawal.

Contrary to the above, from May 18, 1991 until June 3,

1991, with the Reactor Trip System breakers closed and the Control Rod Drive System capable of rod withdrawal,'nly one automatic trip instrumentation channel was operable because of a damaged undervoltage output card on the other channel caused by improper maintenance activities.

Admission or Denial of the Violation:

CP&L admits to the violation.

Reason for Violation A:

NRC IE Information Notice 85-18, issued on March 7, 1985, provided information about potential Undervoltage (UV) driver output card damage caused by maintenance on the reactor trip breakers.

This information was further detailed in Westinghouse Technical Bulletin*NSID-TB-85-16 issued July 31, 1985.

Westinghouse recommended that maintenance on the reactor trip breakers be performed. with the UV card pulled from its slot or that Solid State Protection System (SSPS) logic testing be performed after maintenance to verify operability.

In addition, modified UV boards with a fusible link which prevent closure of the reactor trip breaker upon failure, were subsequently procured from Westinghouse.

In response to the Technical Bulletin and Information Notice, SHNPP indicated that it was not a good maintenance practice to remove SSPS boards.

Removal of the boards was considered unnecessary since post maintenance testing was routinely performed after any plant maintenance to verify equipment operability.

On May 18, 1991, with the Reactor Coolant System at normal operating temperature and pressure, Reactor Trip Breaker A would not close in preparation for Hot Control Rod Drop Testing.

Investigation resulted in the replacement of the spring latch coil in the breaker and the manual control switch on the Main Control Board.

It is believed that this maintenance performed on Reactor Trip Breaker A caused an inadvertent shorting to ground Page 1 of 4

of the UV card output.

Troubleshooting involved disconnecting the primary and secondary contacts as the breaker was racked out on it's rails.

Power was then provided to the closing coil (125 volts DC) and the undervoltage trip coil (48 volts DC) via jumpers from the cabinet terminal board to the appropriate breaker termination points. It is highly likely that shorting of the 48 volt power to ground occurred during installation or removal of these jumpers.

This caused a short as described in Westinghouse Technical Bulletin NSID-TB-85-16.

Therefore, the UV card output remained high, preventing the passage of a reactor trip signal through SSPS Train A.

Appropriate precautions were not added to Maintenance procedures used in troubleshooting or testing of the reactor trip breakers upon issuance of Westinghouse Technical Bulletin NSID-TB-85-16.

The item was addressed by stating that post maintenance testing would verify SSPS operability.

In the situation on May 18,

1991, Operations and Maintenance personnel made a

conscious decision to eliminate the prescribed SSPS logic testing because they assumed that only the components downstream of the SSPS could have been 4 affected by the maintenance.

Train A of SSPS was last verified operable by the performance of MST-I0001 on May 16, 1991.

Based on the assumption that the reactor trip breaker maintenance damaged the UV card on May 18, 1991, Train A of SSPS was unable to perform its automatic reactor trip safety function from May 18; 1991 to June 3,

1991.

Train B of SSPS was operable during this period to provide the redundant channel of reactor protection.

The manual reactor trip function was also fully operable during this period.

VIOLATION B:

Technical 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, Paragraphs l.j and 9 requires procedures for the control of electrical jumpers.

Administrative Procedure AP-24, Temporary Bypass, Jumper and Wire Removal Control, Section 3.2.1, requires that maintenance personnel ensure that operations personnel are properly notified and appropriate parts of form AP-24-1 are completed prior to placement or removal of any electrical jumpers.

Plant Program Procedure PLP-400, Post-Maintenance

Testing, requires that appropriate testing be performed following the conduct of maintenance to verify affected equipment is capable of performing its intended function.

Contrary to the above, applicable maintenance procedures were not followed as evidenced by the following examples:

On May 18, 1991, during corrective maintenance activities associated with the train "A" reactor trip breaker and control switch replacement, the operations staff was not informed that electrical jumpers had been connected to the Reactor Trip System outputs and Form AP-24-1 was not Page 2 of 4

2.

completed to document the various electrical jumpers that were installed in the Reactor Trip System.

On May 18, 1991, testing following corrective maintenance on the train "A" reactor trip breaker was not adequate to verify that Reactor Trip System solid state protection circuitry was capable of performing its intended function.

3.

On May 18, 1991, testing following corrective maintenance to replace a

manual trip switch for the Reactor Trip System was not adequate to test both the undervoltage and shunt trip functions for both trains.

Admission or Denial of the Violation:

CP&L admits to the violation.

Reason for Violation B:

Procedure AP-024 establishes controls for use of temporary bypasses,

jumpers, and wire removal control in the plant.

As provided for in the scope of AP-024, lifted leads are exempted from the control of AP-024 when used for troubleshooting Technical Specification equipment that has been declared inoperable

- as long as the technician remains in the work area to maintain control of the lifted lead.

Procedure AP-024 did not exclude jumpers when used for a similar purpose.

However, plant practice did allow the usage of jumpers in the same manner as lifted leads during troubleshooting.

Following maintenance on May 18,

1991, the post maintenance testing of Reactor Trip Breaker A did not include SSPS logic testing.

Personnel incorrectly determined that the logic testing was unnecessary since only the closing circuit had been repaired.

The post maintenance testing verified that the close circuit problem was corrected but failed to detect the problem in the SSPS undervoltage output driver card.

During the investigation of the maintenance performed on the Reactor Trip System, it was discovered that the reactor trip/close switch had not been adequately tested following replacement on May 18, 1991.

The post maintenance test that was performed on the reactor trip/close switch verified that both reactor trip breakers opened and closed as the control switch was cycled.

This is the normal post maintenance test used following control switch replacement.

In this instance, it was not recognized that taking the switch to the "trip" position provided two independent open signals to the reactor trip breakers

- the undervoltage trip and the shunt trip.

The testing performed was adequate to verify at least one of these signals functioned but was not adequate to verify that both the undervoltage and shunt trip signals functioned.

Page 3 of 4

Corrective Ste s Taken and Results Achieved A&B The failed Train A UV driver card was replaced on June 4, 1991 with a new fused card as recommended by Westinghouse Technical Bulletin NSID-TB-85-16.

The Train B UV driver card was previously replaced with a modified card on April 5, 1991.

Solid State Protection System logic testing was completed satisfactorily on each train following card replacement.

The reactor trip/close switch was declared inoperable on June 6,

1991 and the reactor was shutdown on June 8,

1991 for switch testing.

The switch testing was completed with satisfactory results and the reactor was returned to power on June 9,

1991.

Corrective Ste s Taken to Avoid'urther Violations A&B The procedure on Temporary Bypass,

Jumper, and Wire Removal (AP-024) has been updated to state that the use of jumpers during troubleshooting is excluded from the scope of AP-024 provided that additional troubleshooting guidelines are followed.

An umbilical cord will be*manufactured to supply 125V DC for reactor trip breaker maintenance and troubleshooting.

This umbilical cord will not connect to the 48V SSPS output.

A temporary 48V power supply will be used to supply a

simulated SSPS input signal for any future reactor trip breaker work.

Controls have been established to ensure that SSPS logic testing will be performed as part of the post-maintenance testing that follows any work on the reactor trip breakers.

If testing the SSPS logic is determined unnecessary, it can be deleted only with the Manager

- Operations approval.

Appropriate site personnel involved in maintenance and modification work onsite have been sensitized to this event and the requirement that post-maintenance/post-modification testing be extensive enough to ensure no additional problems are created by the maintenance or modification activities.

Date When Full Com liance Will Be Achieved A&B Full compliance is pending the manufacturing of the umbilical cord for reactor trip breaker maintenance and troubleshooting as stated above.

This action will be completed*by September 30, 1991.

Page 4 of 4