ML18005A299

LER 88-001-00:on 880115,emergency Operating Procedure (EOP) Deficiency for Switchover to Recirculation After LOCA Discovered.Caused by Failure to Incorporate FSAR Change Into Plant Procedures.Eops revised.W/880215 Ltr

ML18005A299
Person / Time
Site:	Harris
Issue date:	02/15/1988
From:	Howe A, Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
HO-880057-(O), LER-88-001-02, LER-88-1-2, NUDOCS 8802230245
Download: ML18005A299 (11)

Text

0 REGULATORY INFORMATION DISTRIBUTION SYSTEM (BIDS)

ACCESSION NBR: 8802230245 DOC. DATE: 88/02/15 NOTARIZED: NO DOCKET FACIL: 50-400 Shearon Harris Nuclear Poeer Planti Unit ii Carolina 05000400 AUTH. NAME - AUTHOR AFFILIATION HOWE'. Carolina Poeer & Light Co.

WATSONI R. A. Carolina Power & Light Co.

RECIP. NAME'ECIPIENT AFFILIATION

SUBJECT:

LER 88-001-00: on 880115'mergency operating procedure (EOP) deficiency for seitchover to recirculation after LOCA discovered. Caused bg failure to incorporate FSAR change into plant procedures. EOPs revised. W/880215 ltr.

DISTRIBUTION CODE: IE22D COPIES RECEIVED:LTR J ENCL I SIZE: ID TlTLE: 50. 73 Licensee Event Report (LER)z Incident Rpti etc.

NOTES: Application for permit reneeal f iled. 05000400 REC IP IENT COPIES 'RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 PD2-1 PD 1 1 BUCKL'EY> B 1 1 INTERNAL: ACRS MICHELSON 1 1 ACRS MOELLER 2 2 AEOD/DOA 1 1 AEOD/DSP/NAS 1 1 AEOD/DSP/RQAB 2 2 AEOD/DSP/TPAB ARM/DCTS/DAB 1 1 DEDRO 1 NRR/DEBT/*DS 1 0 NRR/DEST/CEB 1 1 NRR/DEST/ELB 1 NRR/DEST/ I CSB 1 1 NRR/DEST/MEB 1 1 NRR/DEST/MTB 1 NRR/DEST/PSB 1 1 NRR/DEST/RSB 1 1 NRR/DEST/SGB 1 1 NRR/DLPG/HFB 1 1 NRR/DLPG/GAB 1 1 NRR/DOEA/EAB 1 NRR/DREP/R*B 1 1 NRR/DREP/RPB 2 2 NRR/DRIS/SIB 1 NRR /P MAS/ ILR8 1 1 1 RES TELFORDi J 1 1 ES/DE/EIB 1 1 RES/DRPS DIR 1 1 RGN2 FiLE 01 1 1 EXTERNAL: EG&G GROHi M 5 5 FORD BLDG HOYLE A 1 1 H ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC HARR IS. J 1 1 NSIC NAYS> G 1 TOTAL NUMBER QF.COPIES REQUIRED: LTTR 46 ENCL 45

NRC Form 355 UA. NUCLEAR REOULATORY COMMISSION (903) APPROVED OMB NO. 31500)OI EXPIRES: 5/31/SS LICENSEE EVENT REPORT (LER)

DOCKET NUMBER (2) PA E 3 FA<<L>>YNA"<<>> SHEARON HARRIS POWER PLANT UNIT ONE 0 5 0 0 0 1 OF EMERGENCY OPERATING PROCEDURE DEFICIENCY FOR SWITCHOVER TO RECIRCULATION AFTER A N

EVENT DATE (5) LER NUMBER (SI REPORT DATE'7) OTHER FACILITIES INVOLVED (Sl MONTH OAY YEAR YEAR >c SSOUKNTSAL Revs~

'cc: NUMeeR MONTH DAY YEAR FACILITYNAMES OOCKFT NUMBER(SI NUMBER 0 5 0 0 0 0 1 1 588 88 001 0 0 0 2 1 5 8 8 0 5 0 0 0 THIS REPORT IS SUBMITTED PURSUANT TO THE REOUIREMENTS OF 10 CF R (I: (Ch<<k one or more of the follovflnPI (11)

OPERATING MODE (9) 20A02(e) 20AOS(cl 50.734) (2) (Iv) 73.71(e)

POWER 20AOS (e)(1 l(0 SOM(cl(1) 50.73(el(2)(v I 73.71(cl LEUEL 1 0 0 OTHER (Specify In Aestrect (10) 20AOS(el(1)(4) 50.35(cl(2) 50.73(el(2)(vli) helovr end In Text, HIIC Form 20A05(e) (I l(iii) 50.73(el(2)(i) 50.73(el(2)(viiil(A) SSSA) 20AOS(el(1 l(iv) 50.73(e l(2) (ii) 50,73(e) (2((vill)(8) 20AOS (e I (1 I (v I 50.73(el(2) (Iii) 50.73(e) (2 I (x)

LICENSEE CONTACT FOR THIS LER I12)

NAME TELEPHONE NUMBER ANDREW HOWE SR. ENGINEER REGULATORY COMPLIANCE AREA CODE 91 936 2- 2719 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE; >N5%:, MANUFAC. EPORTASLE CAUSE SYSTEM COMPONENT MANUFAC TURER TO NPRDS (c)'>

xg

. CAUSE SYSTEM COMPONENT TUBER TO NPRDS SUPPLEMENTAL REPORT EXPECTED Ile) MONTH S~S DAY YEAR EXPECTED SUBMISSION DATE (15)

YES (If yes, complete EXPECTED SIIShtISSIOH DATE/ NO ABSTRACT (LImit to tc00 speces, I e., epproxlmetely fifteen tlnple specs typervrltten Ilneel (19)

On January 15, 1988, it was discovered that a procedure deficiency had previously existed in the Emergency Operating Procedures (EOPs) which could have resulted in the failure of the Emergency Core Cooling System (ECCS) during the recirculation phase of an accident, under a scenario of a single failure of one Residual Heat Removal Pump (RHRP). The deficiency involved an improper valve lineup which could cause a RHRP to exceed its design flow limit during ECCS recirculation, if one of the two RHRPs had failed during a loss of coolant accident (LOCA) leaving only one operating RHRPP and if the LOCA was sufficiently large to completely depressurize the Reactor Coolant System.

This procedure deficiency resulted from the failure to completely incorporate into plant procedures a change made to the Final Safety Analysis Report.

The deficiency existed beginning in December of 1986, when the EOP containing the error was approved, and initial operation of the plant began. When the safety significance of the discrepancy was discovered, the EOPs were revised to correct the error. This occurred on December 16, 1987.

Other FSAR changes made in this time period involving a change to procedures were reviewed to ensure they were properly implemented. Members of the Plant Nuclear Safety Committee have been advised of this situation and reminded of their responsibility regarding the reportability of such situations'RC 8802230245 880215 PDR ADOCK 05000400 S

Form 355

NRC fIfIA SCCA U.S. NUCLEAR REOULATORY COMMISSION (043 l LICENSEE EVENT REPORT {LER) TEXT CONTINUATiON APPROVED OMS NO. 3150WIOC EXPIRES: 0/31/(6 fACILITYNAME ill DOCKET NUMSER (2I LER NUMSER (5) PACE (3I YEAR CCOVCNT/AL AEVI5ION NUM C II Nl/M N SHEARON HARRIS NUCLEAR POWER PLANT C UNIT ONE 0 0 0 2 OF 0 o s o o o 4 0 0 8 8 0 0 1 6 TEXT ////IIPIP N>>cf /I IPCMCPI/. VffR(5C/fnel H/IC form 3HIA'f/(IT)

DESCRIPTION:

Note.'The following drawings supplement the narrative of this report:

Attachment A - ECCS Recirculation Flowpath Existing Prior to September 1986 Attachment B ECCS Recirculation Flowpath Required in FSAR After September 1986 Attachment C - ECCS Recirculation Flowpath Implemented in Procedures, December 1986 The switchover procedure for transferring the Emergency Core Cooling System (ECCS) from injection to recirculation is outlined in FSAR Table 6.3.2-6. The initial practice required closing isolation valves to separate the ECCS headers into two separate trains, thus providing protection for passive failures of the piping. The resulting valve lineup for recirculation is shown in Attachment A. On September 27, 1985, and on August 21, 1986, Westinghouse Electric Corporation, the Nuclear Steam Supply System designer for the Shearon Harris Nuclear Power Plant (SHNPP), issued letters (serial CQL-9018 and CQL-9445) to Ebasco Services, Inc., the architect/engineer for SHNPP. The letters documented recommendations for changes to the procedure described in FSAR Table 6.3.2-6 for the switchover. Westinghouse recommended deletion of the procedure steps which separated the two ECCS trains, since these steps did not provide complete passive failure protection, and since their elimination would allow a single RHRP to supply both CSIPs. In addition, the second correspondence identified the need for new check valves to be installed in the piping connecting the discharge of an RHRP to the CSIP suction, to prevent potential backflow through an idle RHRP during recirculation.

These proposed changes were approved for implementation at SHNPP, since they improved operational flexibility following an accident. In addition, a separate issue regarding requirements for local leak rate testing (LLRT) on ECCS containment penetrations was also resolved by implementing this proposed change.

NRC fORM 3CCA eU.S.OPO:1055W52l 530/155 (043 I

NRC POrAl 344A US. NUCLEAR REOULATORY COMMISSION 104)3)

LICENSEE EVENT REPORT ILER} TEXT CONTINUATION APPROVED OMB NO. 3150&104 EXPIRES: 8/31/IEI PACILITY NAME 11) DOCKET NUMBER I2) LER NUMBER (4) PACE (3)

SHEARON HARRIS NUCLEAR POIItER PLANT yEAR ~sR 44QVENT/AL

~?? NVM ER i . /IEV/4/CN

)@ NVM EN UNIT ONE o s o o o4 00 8 8 0 1 0 0 0 30F 0 6 TEXT /8'/NP/0 N>>C ~ /4/PIP/PPE P44 OANOnel ///IC Ans 3034'4/ IIT)

DESCRIPTION: (continued)

An FSAR change (serial HPOS-845) was initiated to incorporate these changes.

As part of the review of these changes, Technical Support determined that a single RHRP could not supply two CSIPs and both low pressure ECCS injection headers, as the proposed recirculation lineup required. However, by isolating one of the two low pressure safety injection (LPSI) header containment isolation valves, an acceptable configuration was created. This revised lineup demonstrated that the RHRP would not run out (Preoperational Test 2085-P-05, completed October 5, 1986). Therefore, the FSAR change included the new requirement to close one of the two LPSI containment isolation valves to ensure that runout of the RHRP would not occur during recirculation if the other RHRP failed.

This change was incorporated into the FSAR change which was approved on September 24, 1986. A letter was also submitted to the NRC describing this change.

The change required significant revisions be made to the EOPs', however, due to other commitments, revisions were already in progress. The additional changes required due to the FSAR change were not therefore formally identified and tracked. On December 22, 1986, Revision 2 to procedure EOP-EPP-010, Transfer to Cold Leg Recirculation, was issued. However, the revision did not fully implement the requirements of the FSAR in that the requirement to close one LPSI containment isolation valve, identified in FSAR change HPOS-845, was not included. The procedure change package references this FSAR change in its safety analysis, but the engineers developing the procedure revision were not fully cognizant of all the new requirements.

The SHNPP On-site Nuclear Safety (ONS) unit was responsible for the review of INPO Significant Event Reports (SER), and during review of SER 2-87, they identified the discrepancy between the FSAR and the EOPs. On July 10, 1987, an action item was established for the plant engineering department to evaluate the discrepancy to determine whether the procedure or the FSAR was inaccurate. On December 3, 1987, the engineering department confirmed the deficiency was in the EOPs.

NRC PORM 344*

1083) t U.S.OPO:1085.0524 538/455

NRC Fans 300A US. NUCLEAR REOULATORY COMMISSION (003 l LICENSEE EVENT REPORT ILERI TEXT CONTINUATION APPROVEO OMS NO. 3IEOW(04 EXPIRES: 0/31/%

FACILITY NAME (Il OOCKET NUMSER (2l LER NUMSER (0) ~ AOE I3) saavENTIAL sKV>>ION NUM ER nvM Es SHEARON HARRIS NUCLEAR POWER PLANT UNIT ONE 0 5 0 0 0 4 0 0 8 8 0 1 0 004 oF0 TEXT ///more <<>>ca II mavkw/, oaa Ada/h/ana///hC Fons 3///)A3/ (IT)

DESCRIPTION: (continued)

Separately, Operations personnel noted that the Monitor Light Box (MLB) for ECCS recirculation was engraved to require one LPSI containment isolation valve to be close while the other was open. Believing this to be a simple engraving error, a Plant Change Request (PCR) (serial PCR-2384) was initiated on September 25, 1987, to change the engraving to require the valve to be open during recirculation, in agreement with the plant EOPs. The PCR was rejected by Technical Support personnel, since they were aware of the previous FSAR change requiring the valve to be closed to prevent RHR pump runout. The Operations engineer who initiated the PCR then wrote a feedback report (serial 305) in accordance with plant procedure OMM-001, Operations " Conduct of Operations, on October 26, 1987. A procedure change was determined to be required, and was to be addressed in the next revision which was to be issued in the fall of 1988.

In both cases, personnel were not cognizant of the safety significance of the procedure deficiency.

However, when ONS received the response for INPO SER 2"87 from engineering on December 3, 1987, the ONS unit contacted Operations and made them aware of the serious nature of the deficiency. A change to procedure EOP-EPP-010 was issued on December 16, 1987, correcting the error and making the procedure consistent with the FSAR. In addition, procedure EOP-EPP-003, Loss of All AC

~

Power Recovery with Safety Injection Required, which also addresses the recirculation lineup, was issued on January 6, 1988.

On January 15, 1988, this matter was discovered by Regulatory Compliance personnel. The situation existing for nearly one year in which the emergency operating procedures were in disagreement with the FSAR was investigated and determined to be reportable.

SAFETY SIGNIFICANCE:

The ECCS, and hence all procedures governing operation of this system, were required to be in place when the plant first entered Mode 4 in December of 1986, as per Technical Specification 3.5.3. In the event of a large break loss of coolant accident simultaneous with the single failure of an RHRP, when the recirculation phase of ECCS operation was initiated in accordance with plant procedures, the plant would have been in an unanalyzed condition.

The single operating RHRP could have exceeded its design flow limit, which would cause the RHRP to trip on overcurrent, subsequently causing the failure of the CSIPs, since these pumps rely on the RHRP as the source of water for recirculation operation. Operator action outside of plant procedures would have been required to recover the situation. The RHRP would be available once the operator had reset the overcurrent trip.

NRC FORM 340A o U.S.OPO:10SHH2A.S30/4dd (043)

NRC FOtIA 3EEA, UAL NUCLEAR REOULATORY COMMISSION

/043)

LICENSEE EVENT REPORT {LER) TEXT CONTINUATION APPROVED OMS NO. 3180W104 EXPIRES: 8/31/88 FACILITY NAME III DOCKET NUMSER I2) LER NUMSER (EI PACE ISI SHEARON HARRIS NUCLEAR POWER PLANT YEAR @.: SEQUENTIAL " IIEVISION NUM EII 8 NUM EII UNIT ONE 0 5 0 0 0 P 0 0 001 0 0 05 o" 0 TEXT /I/ mSIS SPECS /S /NPIPWE IMP SdtAMNM//VIICAVm 3R/A3/ I ITl SAFETY SIGNIFICANCE: (continued)

The following indications would have been available to the operator to alert him of the problem'.

Flow indication for the RHRP Motor amperage indication for the RHRP Alarms for the MLB due to the valve lineup error Alarm for the RHRP tripping The condition is reportable in accordance with 10CFR50.73(a)(2)(v) as a procedural error which could have prevented the fulfillment of the safety function of systems which mitigate the consequences of an accident.

CAUSE'here is no single reason that this procedure deficiency came into existence, but the following contributed to the error.

1. Personnel responsible for the EOPs were aware of the Westinghouse proposals to revise the ECCS recirculation lineup, and when the FSAR was changed to implement this new lineup the additional requirement to close the LPSI isolation valve was not noted. The modification to close one of the two LPSI containment isolation valves affected only one page of a change package which was 32 pages in length, and the majority of this package discussed containment isolation valve design, not ECCS recirculation procedures.

2. Changes made to the FSAR, which would require changes to plant procedures, were not routinely identified and tracked prior to licensing of the plant due to the significant number of changes and due to the fact that procedures were being revised prior to initial use in preparation for the operation of the plant.

3. FSAR changes are not immediately made available in the copies of the FSAR, since updates are only required annually by regulations.

The discrepancy between the FSAR and EOPs was identified by many groups during 1987. However, the technical issue as to which document was accurate was not obvious. Investigation of the discrepancy was not given appropriate urgency, given the potential consequences of the discrepancy. When the investigation was completed, the problem was corrected within a reasonable period of time, but the potential reportability of the situation was not identified.

No similar situations have previously occurred.

NIIC POIIM 344A AU.S.OPO;1080O824 838/4dd I843 I

NRC form 388A US. NUCLEAR REOULATORY COMMISSION IE83 I LICENSEE EVENT REPORT (LERI TEXT CONTINUATION APPROVED OMS NO. 3180&)85 EXPIRES: 8/3) IES FACILITY NAME III DOCKET NUMSER Ill LER NUMSER (8) IIAOE I3)

SHEARON HARRIS NUCLEAR POWER PLANT YEAR 5COVCNTIAL NUM 5 Ir IICVI5ION NVM CII UNIT ONE o s o o o 400 0 1 000 oF 06 TEXT INmore e>>ce ic eeerrierf. Iree FIF8eovNF HRC forrrr ~'cl I IT)

CORRECTIVE ACTIONS:

The EOPs were revised prior to the discovery of this situation.

The events which led to this procedure deficiency occurred prior to licensing of the plant. Upon issuance of the operating license, many changes went into effect regarding how plant design changes are controlled:

Changes to the plant components which require a PCR receive a complete safety analysis in accordance with 10CFR50.59.

PCRs are reviewed by the appropriate units to determine the impact on plant procedures for which they are responsible.

FSAR changes now follow, rather than precede, the changes made to the plant and/or procedures.

The following additional measures are to be taken'.

Changes to the FSAR approved in 1986 have been reviewed to verify that those changes which alter procedures described in the FSAR were properly implemented in the plant. No similar situations were discovered.

Members of the Plant Nuclear Safety Committee have been informed of this event and reminded of their responsibility to ensure potentially reportable items are brought to the attention of management.

NIIC POIIM 355A *U.S.OPO;1888 0 825 838MSS

)183)

BIT LER 88-001 ATTACHMENT A COLD LEG ECCS RECIRCULATION FLOWPATH EXISTING PRIOR TO SEPTEMBER 1986 1B-SB HPSI-IOT LEG 1C-SAB INSIDE CONTAINMENT CONTAINMENT 1A-SA RECIRCULATICN IfSl-COLD LEG SUMPS CHARGI NG/Sl PUMPS I

HX LPSI-COLD LES 1B-SB LPSI" RHR PUMPS HOT LEG HX LPSI-COLD LEG IA-SA INSIDE CONTAINMENT

BIT LER 88-001-00 ATTACHMENT B IPSI.

ECCS RECIRCULATION FLOWPATH COLO QG REQUIRED IN FSAR AFTER SEPTEMBER 1986 I B-SB HPSI-IO'I LIG 1C-SAB INSIDE CONTAINt1ENT CONTAINMENT 1A-SA PEPSI RECIRCULATION COLO llG SUl1P8 CHARGING/S I PUMPS isi-~I HX U'SI-COLD LEG IB-SB

~:

LPSI-RHR PUMPS INT LEG lsi-swo HX LPSI-ID LEG IA-SA INSIDE CONTAINMENT

BIT LER 88-001-00 ATTACHMENT C ICOSI ECCS RECIRCULATION FLOWPATH CQ.D GG IMPLEMENTED IN PROCEDURE, DECEMBER 1986 'I B-SB HPSI-HOT LfG 1C-SAB INSIDE CONTAINt1ENT CONTAIHMEHT 1A-SA tPSI RECIRCULATION COLD LEG SUMPS CHARGING/Sl PUMPS LPSI-COLDLEG 1B-SB LPSI-RHR PUMPS HOT LEG HX LPSI-COLD lEG IA-SA INSIDE CONTAINMENT

Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.O. Box 165 New Hill, NC 27562 FEB i." l9se File Number'SHF/10-13510C Letter Number: HO-880057 (0)

U.S. 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 88-001-00 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.

R. A. Watson Vice President Harris Nuclear Project MGW:sbg Enclosure cc: Dr. J. Nelson Grace (NRC - RII)

Mr. B. Buckley (NRR)

Mr. G. Maxwell (NRC - SHNPP)

MEM/LER-88"001/1/Osl