ML18005A199

Forwards 871021 Enforcement Conference Summary Re Loss of Steam Generator Blowdown Isolation Capability Between 870813 & 0913.Review of Issues Will Be Continued to Determine Appropriate Enforcement Actions.W/List of Attendees

ML18005A199
Person / Time
Site:	Harris
Issue date:	11/04/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Utley E CAROLINA POWER & LIGHT CO.
References
NUDOCS 8711130112
Download: ML18005A199 (17)

Text

W') )g REGULA Y INFORMATION DISTRIBUTI YSTEM (RIDS>

ACCESSION NBR: 8711130112 DOC. DATE: 87/11/04 NOTARIZED:

NO FACIL: 50-400 Shearon Harris Nuclear Power Planti Unit 1I Carolina AUTH. NAME AUTHOR AFFILIATION GRACEI J. N.

Region 2I Ofc of-the Director REC IP. NAME RECIPIENT AFFILIATION UT LE YI E. E.

Carolina Pacer gv. Light Co.

DOCKET ¹ 05000400'UBJECT:

Foreards 871021 enforcement conference summary re loss of steam generator bloedoen isolation capability between 870813 5 0913. Review of issues mill be continued to determined appropriate enforcement actions. N/list of-attendees.

DISTRIBUTION CDDE:

IEOID COPIES RECEIVED: LTR I

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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit reneujal filed.

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gov 04 198'1 Docket No. 50-400 License No.

NPF-63 Carolina Power and Light Company ATTN:

Mr. E.

E. Utley Senior Executive Vice President Power-Supply and Engineering and Construction P. 0.

Box 1551

Raleigh, NC 27602 Gentlemen:

SUBJECT:

ENFORCEMENT CONFERENCE

SUMMARY

(NRC INSPECTION REPORT NO. 50-400/87-34)

This letter refers to the Enforcement Conference held at our request on October 21, 1987.

This meeting concerned activities authorized for your Shearon Harris facility.

The issues discussed at this conference related to a loss of steam generator blowdown isolation capability between August 13 and September 13, 1987.

A summary, a list of attendees and a copy of your handout are enclosed.

It is our opinion that this meeting was beneficial and has provided a better understanding of the inspection

findings, the enforcement

issues, and the status of your corrective actions.

We are continuing our review of these issues to determine the appropriate enforcement action.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

Should you have any questions concerning this letter, please contact us.

Sincerely,

Enclosures:

1.

Enforcement Conference Summary 2.

List of Attendees 3.

Handout cc w/encls:

(See page 2) 8711130112 871104 PDR ADOCK 05000400

'8 PDR J.

Nelson Grace Regional Administrator

NOY 0 4 198'l Carolina Power and Light Company cc w/encls:

R. A. Watson, Vice President Harris Nuclear Project D. L. Tibbitts, Director of Regulatory Compliance J.

L. Willis, Plant General Manager bcc w/encls:

C. Barth, OGC NRC Resident Inspector

. A. Upchurch, Chairman, Triangle J Council of Governments J.

Liberman, DOE G.

R. Jenkins, EICS Document Control Desk State of North Carolina RI S

as:er 10+/87 RI I ~

RI I PF dri ckson DVerre1 1 i 10/~/87 10/y/87 RII RI 6

LReyes Jen 10/)'-" /87 10/gO/87 RI I r~ ~/87

gpss 04 $8'I ENCLOSURE I ENFORCEMENT CONFERENCE

SUMMARY

The Regional Administrator opened the meeting by emphasizing that all licensees must interpret and follow their Technical Specifications correctly, and speci-fically, that Harris, being an NTOL plant must pay special attention to regulatory compliance.

Carolina Power and Light Company (CP&L) then initiated their presentation with,a description of the Harris steam generator blowdown system and also the design principles for General Design Criteria (GDC) 55 and 56 (two valve line) and GDC 57 (one valve line).

The chronology of the event was then discussed, especially the involvement of the Onsite Nuclear Safety (ONS) organization.

ONS was asked specifically about their concerns in this matter and whether the plant staff had reacted appropriately to the concern expressed.

The ONS representative stated that the plant had done a thorough job in evaluating the concerns brought up by ONS and acted on them in a responsible manner.

The question was then asked as to exactly how CP&L had interpreted Technical Specification 3.6.3 for this event.

CP&L stated that since this requirement (with the addition of Note 6 in the implementing procedure) was written to handle both two valve and one valve lines, they assumed that all action state-ments for the two valve system would be mirrored for the one valve system and

thus, in the case of a closed

system, the closed system could act as both the operable isolation valve and also as the automatic valve which was required to be secured in the isolated position.

This interpretation had not been previ-ously presented to Region II personnel.

CP&L stated that this interpretation had been used to make the decision that the unit was in compliance with Technical Specification 3.6.3 during the time that valve IBD-11 was inoperable.

The licensee also stated that they had made their decision on this Technical Specification in good faith and that, at the time the decision was made, they had no reason to believe that their interpretation was incorrect.

In that this position was new information to the Region II staff, CP&L stated that they would provide a letter to Region II, in approximately a week, discussing the deliberation process used by the operation and plant management staff to reach this interpretation in this particular case.

The meeting was concluded by the Regional Administrator.

g0y 04 ASS'I ENCLOSURE 2

LIST OF ATTENDEES CP&L M. A. McDuffie, Senior Vice President

- Nuclear Generation R. A. Watson, Vice President - Harris Nuclear Power Plant J. L. Willis, Harris Plant General Manager S.

R.

Zimmerman, Manager - Nuclear Licensing H.

W. Bowles, Assistant to Chairman/President 0;

C. McCarthy, Principle Engineer - Nuclear Licensing C. S.

Bohanan, Harris Director of Special Projects G. A. Sinders, Director, Harris Visitors Center NRC Re ion II J.

N. Grace, Regional Administrator A. F. Gibson, Director, Division of Reactor Safety (DRS)

D.

M. Verrelli, Branch Chief, Division of Reactor Projects (DRP)

R. J.

Godard, Regional Councel G.

R. Jenkins, Director, Enforcement and Investigative Coordination Staff P.

E. Fredrickson, Section Chief, DRP G.

F. Maxwell, Harris Senior Resident Inspector, DRP S.

P. Burris, Harris Resident Inspector, DRP S. J. Vias, Project Engineer, DRP K. L. Whitener, Reactor Inspector, DRS P. Taylor, Reactor Inspector, DRS NRC Head uarters B.

C. Buckley, Harris Project Manager, Office of Nuclear Reactor Regulation W.

M. Troskoski, Regional Coordinator, Office of Executive Director for Operation

ENCLOSURE 3

NOV 04 188't CPaL PRESENTATION ON 80-11 DESCRIPTION Of SG BLOMDOWN LINES AT SHNPP

~

IMPLEMENTATION OF GDC 57 'T SHNPP AND HARRIS INTERPRETATION OF TECH SPEC 3e6e3 CHRONOLOGY OF BD-11 EVENTS PLANT MANAGEMENT DIRECTION SINCE SEPTEMBER 11'987

SUMMARY

AND ASSESSMENT OF SAFETY CONSEQUENCES

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CONTAINMENT SYSTEMS 3/4.6.3 CONTAIeaun ISOLATION VALVaS IIMITIHCCONDITION FOR OPERATION 3.6.3 The containment isolation valves specified in

'Table 3.6-1 shall be OPERABLE vith isolation times as shown in Table 3.6-1.

APPLICABIL'ITY: MODES 1, 2, 3>'and 4 ~

ACTION:

With one or more of the containment isolation valve(s) specified in Table 3.6-1 inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and!

a.

Restore the inoperable valve(s) to OPERABLE status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or b.

Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve secured in the isolation position, or c.

Isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual valve or blind flange, or d.

Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 bourse'

SURVEILLAMCE RE UIREMEHTS 4 ~ 6 ~ 3 ~ 1 The isolation valves specified in Table 3.6-1 shall be demonstrated OPERABLE prior to returning the valve to service after maintenance,

repair, or replacement work is performed on the valve or its associated

actuator, control, or power circuit by performance of a cycling

test, and verification of isolation timei (6)

For this valve>

the closed system in which it is. located is considered to be an OPERABLE isolation valve for purpose of compliance Mith the ACTION statementi

KFY BO-Il DATES AUGUST 13, 1987 BO-11 FAILS,IN OPEN POSITION INITIATED EQUIPMENT INOPERABLE RECORD (EIR

)e SHIFT FORENAN CONSULTS WITH REGULATORY COMPLIANCE

~

AUGusT 281 1987 ONS RAISES CONCERNS ON ACCIDENT ANALYSIS

~

AUGUsT 3li 1987 INITIAL HESU EVALUATION -

NO PROBLEM SEPTEMBER 1~

1987 FURTHER DISCUSSIONS MERE HELD WITH ONS AND HESU REQUESTS ASSISTANCE FROM NUCLEAR FUELS SECTION (NFS)

~

SEPTEMBER 4i 1987 ONS~

PGNi OTHER NEET TO DISCUSS ISSUE FIRST NFS ANALYSES -

NO PROBLEN

~

SEPTEMBER 9i 1987 ONS MEMO TO PGHo QUESTIONS ON OPERATION MITH BD-II OPEN

~

SEPTEMBER 9y 1987 IBD 7 (4 INCH LINK) CLOSED AND DEENERG IZED

SEPTEMBER llew 1987 INITIAL NRC NOTICE OF UNANAIYZED COND IT ION ON 0 INCH LINE WHEN NFS ANALYSIS DONE SEPTEMBER ll, 1987 PLANT SHUTDOWN ORDERED BY PGN DUE TO CONTINUING ANALYTICALQUESTIONS'

ASSESSMENT OF SAFETY CONSEQUENCES LEVEL OF SAFETY THROUGHOUT WAS ALWAYS THE SAME AS THAT PROVIDED FOR GDC 55 AND 56 PENETRATIONS IN SAME COND IT I ONS I ANALYSES SHOWED ADDITIONAL FAILURE OF 0 INCH LINE UNACCEPTABLE WITH TOTAL FAILURE OF BLOWDOWN LINE INCH LINE CLOSED WHEN ISSUE WAS RAISED DID NOT WAIT fOR FINAL ANALYTICALRESULTS SHNPP HAS ADDED WHAT IS IN EFFECT AN LCO FOR THESE VALVES TO OUR INTERPRETATION

OPERATION OF PLANT WAS CONSISTENT WITH TECH SPECS AS WE UNDERSTOOD THEM INTERPRETATION DEVELOPED PRIOR TO 8D-11 FAILURE CONSEQUENCES OF ADDITIONAL FAILURE OF BDl AND BD7 NOT CONSLDERED IN FSAR OR TECH SPEC WHEN QUESTIONS WERE RAISED'EASONABLE STEPS TAKEN TO PURSUE CONCERNS WHEN ANALYSIS QUESTIONS PERSISTED BEYOND A REASONABLE TIMEe PLANT MANAGEMENT"ORDERED THE PLANT TO BE SHUTDOWN WHEN IT BECAME APPARENT THAT NRC DISAGREED WITH OUR INTERPRETATIONS WE REVISED OUR INSTRUCTIONS TO COMPLY WITH YOUR INTERPRETATION

EXAMPLES OF CONSERVATIVE PLNT OPERATION

(

87 HouRS)

( 318 HouRs)

(

171 HOURS)

SHUTDOWNS TO REPA IR AUXILIARY FEEDWATER SYSTEN BACKLEAKAGE MARCH 6, 1987 MARcH 13, 1987 MAY 2, 1987 DETAILED EVALUATION OF SIGNIFICANT FEEDWATER AND CONDENSATE SYSTEH TRIPS PRIOR To RESTART JANUARY 22'987

(

37 HOURS)

MARCH 13'987

( 318 HOURS - AFN CHECK VALVE REPAIR WAS CONDUCTED DURING THE OUTAGE)

MARCH 3li 1987

(

18 hOURS)

APRIL 3, 1987

(

30.3 HouRs)

APRIL 12, 1987

(

10 BouRs)

APRIL III 1987

(

29 HOURS)

APRIL 21'987

(

11 HOURS)

APRIL 22'987

(

29 HOURS)

MAY 20, 1987

(

11 HOURS)

AVERAGE DURATION FOR ALL OTHER TRIPS WAS 12 HOURSe MEN/PRESENT/1/OS1

SHUTDOWNS AND POWER REDUCTIONS TAKEN TO CORRECT EFFECTS-OF CONDENSER TUBE LEAKS JUNE 19, 1987

(

43 HOURS)

JUNE 26, 1987

(

31 HOURS) 0 SHUTDOWNS TO REPAIR STEAM LEAKS ON HAIN TURBINE HAY 2J 1987

(

171 HOURS) - OTHER MAINTENANCE WAS PERFORMED IN THIS OUTAGEo AUGUST 7J 1987

(

43 HOURS) 9UESTIONS ON STEAM 6ENERATOR ISOLATION SEPTEMBER 15'987

( 242 hOURS)

NEH/PRESENT/2/OSl