ML18012A350

Notice of Violation from Insp on 960609-0720.Violation Noted:As of 960703,interlocks Were Not Installed for Preventing Emergency Power Supply Overload as Described in FSAR & Written Safety Evaluation Was Not Recorded

ML18012A350
Person / Time
Site:	Harris
Issue date:	09/06/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18012A349	List: ML18012A348 ML18012A350
References
50-400-96-06, 50-400-96-6, EA-96-261, NUDOCS 9609170207
Download: ML18012A350 (34)

Text

NOTICE OF VIOLATION Carolina Power and Light Company Shearon Harris Unit 1

Docket No.:

50-400 License No.:

NPF-63 EA 96-261 During an NRC inspection conducted on June 9 through July 20, 1996, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions,"

(NUREG 1600),

the violations are listed below:

A.

10 CFR 50.59,

Changes, Tests, and Experiments, requires that licensees maintain records of changes in the facility and that these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.

The Final Safety Analysis Report (FSAR), Section 9.2.2.3, referred to interlocks that are provided to assure that a spare and a dedicated pump in the Component Cooling System are not started by an automatic signal such that the emergency power supply is overloaded.

This design requirement was also specified in design basis document DBD-131, Revision 4, Component Cooling Water System.

Contrary to the above, as of July 3, 1996, interlocks were not installed for preventing emergency power supply overload as described in the FSAR and a written safety evaluation was not recorded.

This condition existed since initial plant operation in 1987.

This is a Severity Level IV Violation (Supplement I).

B.

10 CFR 50, Appendix B, Criterion III, Design Control, requires that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications,

drawings, procedures, and instructions.

It further requires that design

changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design.

1.

Design basis document DBD-103, Revision 2, Chemical

& Volume Control System/

Boron Thermal Regeneration System/

Boron Recycle

System, specified that the spare charging/safety injection pump is interlocked with the dedicated charging/safety injection pump ("A" or "B" pump depending on physical placement of the spare pump's breaker) so that only one pump can be energized from only one emergency bus at a time.

Contrary to the above, as of July 3,

1996, the licensee had not correctly translated the design basis requirement for such an interlock into specifications,

drawings, procedures, or instructions.

As a result, no such interlock was installed for the charging/safety injection pump breakers.

This condition existed since initial plant operation in 1987.

Enclosure 1

9609i70207 960906 PDR ADOCK 05000400 8

PDR

NOV 2.

Safety-related plant drawings 1364-14970, Revision 3, Class 1E 6900V Emergency Bus 1A-SA; and 1364-15658, Revision 4, Class 1E-6900V Emergency Bus 1B-SB, both contain notes referring to key interlocks which prevent inserting breakers into the connected position unless key is in lock.

These interlocks were designated for the spare charging/safety injection pump and the component cooling pump breaker cubicles in each emergency bus.

Contrary to the above, in January 1995, the key interlocks were removed under maintenance work orders from both trains of safety-related 6900V emergency bus switchgear without appropriate design control measures.

The interlocks were installed to provide redundancy and train separation protection.

As of August 1996, these key interlocks were still referenced in the above plant drawings.

This is a Severity Level IV Violation (Supplement I)

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, Harris Nuclear Plant, within 30 days of the date of the letter transmitting this Notice of Violation (Notice),

This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

If the correspondence adequately addresses the required response, your response may reference or include previous docketed correspondence.

If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information, so that it can be placed in the PDR without redaction.

However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the

PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Georgia This 6th day of September 1996 Enclosure 1

LIST OF ATTENDEES NRC L. Reyes, Deputy Regional Administrator, Region II (RII)

D. Verrelli, Acting Director, Division of Reactor Safety (DRS), RII J. Johnson, Acting Director, Division of Reactor Projects (DRP), RII B. Uryc, Director, Enforcement and Investigation Coordination Staff (EICS),

RII N. Shymlock, Chief, Reactor Projects Branch 4 (RPB4),

DRP, RII A. Boland, Senior Enforcement Specialist, EICS, RII C.

Evans, Regional

Counsel, RII J.

Brady, Senior Resident Inspector,

Harris, DRP, RII D. Roberts, Resident Inspector,

Harris, DRP, RII G. HacDonald, Project Engineer,

RPB4, DRP, RII Carolina Power and Li ht Co.

W. Orser, Executive Vice President Nuclear Generation, CP&L W. Habermeyer, Vice President Nuclear Engineering Department W. Robinson, Vice President Harris Plant J.

Donahue, Director Site Operations, Harris Plant T. Walt, Manager, Performance Evaluation and Regulatory Affairs G. Rolfson,

Manager, Harris Engineering Support Services S. Sewell,

Manager, Operations D. Alexander, Supervisor, Licensing and Regulatory Programs T. Cockerill, Superintendent, I&C Electrical Systems H. Avinger, Plant Engineer Enclosure 2

Enclosure 3

PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA SHEARON HARRIS NUCLEAR POWER PLANT AUGUST 22, 1996, AT 10:30 A.M.

NRC REGION II OFFICE, ATLANTA,GEORGIA OPENING REMARKS AND INTRODUCTIONS L. Reyes, Deputy Regional Administrator NRC ENFORCEMENT POLICY B. Uryc, Director Enforcement and Investigation Coordination Staff

SUMMARY

OF THE ISSUES L. Reyes, Deputy Regional Administrator STATEMENT OF CONCERNS / APPARENT VIOLATIONS J. Johnson, Acting Director Division of Reactor Projects LICENSEE PRESENTATION W. Robinson, Vice President

- Harris

."C'arolina Power 5 Light Company BREAK / NRC CAUCUS NRC FOLLOWUP QUESTIONS CLOSING REMARKS L. Reyes, Deputy Regional Administrator

The apparent violation involved:

10 CFR 50.59, Changes, tests and experiments, requires that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report.

These records must include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question.

Final Safety Analysis Report, Section 9.2.2, Component Cooling Water System, indicate that interlocks are provided to assure that both pumps (spare pump and dedicated train pump) are not started by an automatic starting signal such that the emergency power supply is overloaded.

Design basis documents, DBD-103, Chemical

5. Volume Control System/ Boron Thermal Regeneration System/ Boron Recycle System, Revision 2, paragraph 2.3.1.2; and DBD-131, Component Cooling Water System, Revision 4, paragraph 2.3.10, make references to these interlocks.

Both documents indicate that the spare component cooling water and charging/safety injection pumps are interlocked with the dedicated train pumps so that only one pump can be energized from only one bus at a time.

As of July 3, 1996, an unevaluated change in the facility existed regarding the licensee's failure to install diesel generator overload protection interlocks.

This condition existed since original plant construction.

In January 1995, the licensee made a change to the facility by removing Kirk key interlocks from safety-related breaker cubicles, on the charging/safety injection and component cooling water pumps, with out performing an evaluation pursuant to 10 CFR 50.59.

~\\

NOTE:

The apparent violations discussed in this predecisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement decision.

~ BC Pre-decisional Enforcement Conference August 22, 1996

Aena

~ Introductory Remarks - W. R. Robinson e Plant Design - G. A. Rolfson e Plant Operation - S. H. Sewell o Apparent Violation / FSAR Upgrade - T. D. Walt e Closing Remarks - W. R. Robinson

Plant Design

~ Spare pumps installed for CCW and Charging/Safety Injection o Spare pumps have independent power feeds from each electrical train o One circuit breaker provided for each spare motor

~ Spare jumps have independent auxiliary power and instrumentation power feeds from each electrical train

l3esign Considerations for Spare Pumps o Electrical power supply overload o Train separation

Plant Design E3 BUS Electrical Connection Dia ram A BUS BARRIER SA SB ELECTRICAL PULL BOX EMBEDDED CONDUIT FLEX CONDUIT (TYP)~

CAPPED STUB (TYP)

A PUMP

ver oa ro ec ion

verload Protection Desi n Features

. o FSAR description of CCW describes an interlock which prevents two pumps from starting by an automatic starting signal o FSAR description derived from Westinghouse standard system description for CCW

~ Design Basis Documents for CSIP and GGW have similar descriptions of interlocks for overload protection

~ Notes on electrical distribution drawings acknowledge potential for overload

~ Main Control Board alarms provided for both component cooling water and charginglsafety injection iftwo breakers are racked in on the same electrical bus

verloa Protection Main Control Board Alarms - CCW RCPT SEARING CCW HIGH FLOW RCP*BEARNG CCWLOWFLOW RCPS BEARNG CCW HIGH FLOW RCPS BEARNG CCWloWFLOW RCPT BEARNG

~

CCW HIGH FLOW RCPT BEARNG CCW LOWFLOW CCW SURGE TANK HIGSLOWlEVEL CCW PUMPS A DISCHARGE HIGH TEMP CCWPVMPS 8 DISCHARGE HIGH TEMP RCP THERM BAR HDR HCH FLOW RCP BEARNG OUT HCH TEMP RCDT HX CCW HIGH FLOW RCP THERM BAR RCP THERM BAR RCDT HX HDR LOWFLOW OUT HIGHTEMP CCW LOWFLOW COW HEAT EXCHANGERA SERV VWTER HlhP COW HEAT EXCHANGER8 SERV WATER HlhP CCW PUMPS A DISCH HEADER LOW PRESS CCW PUMPS 8 DISCH HEADER LOWPRESS EXCESS LTDNHX CCW HIGH FLOW EXCESS LTDNHX CCWLOWFLOW RHR PUMP A CCWLOWFLOW RHR PUMP 8 CCWLOWFLOW COW HEAT EXCHANGERA SERV WATER HIGHTEMP COW HEAT EXCHANGER 8 SERV WATER HIGH TEMP CCW PUMPS A TROUBLE CCW PUMPS 8 TROUBLE LTDN HX CCW HIGH FLOW RHR HXA OUT HIGHTEMP RHR HXA CCWHVloFLOW RHR HX8 OUT HIGH TEMP RHR HX8 CCW HIA.OFl CCW HEAT EXCHANGERA HIGH FLOW CCW HEAT EXCHANGER 8

~ HIGH FLOW CCW PUMPS A TRIP OR CLOSE CKT TROUBLE CCW PUMPS 8 TRIP OR CLOSE CKT TROUBLE SEAL V%TER HX CCW HIGH FLOW SEAL YATERHX CCWLOWFLOW SPENT FUEL HXA SPENT FUEL HX8 CCWHCH FLOW CCW HIGH FLOW SPENT FUEL HXA SPENT FUEL HX8 CCWLOWFLOW CCW LOWFLOW RECYCLE EVAP CCW HIGH DIFF FLOW CCW HEAT EXCHANGERA OUTlET HIGHTEMP COW HEAT EXCHANGBl8 OUTLET HIGHTEMP CCWTRANA BOTH BKRS N COWTRAN8 BOTH BKRS N COMPUTER ALARM CCW SYSTEMS

verloa Protection Main Control Board Alarms - CVCS.

CHARGING PUMPS DISCH HEADER HIGH-LOWFLOW CSIP RWST SUCTION LCV-1158 PULLTO LOCK CSIP RWST SUCllON LCV-115D PULLTO LOCK BORIC ACID HATCHINGTANK HIGH-LOWTEMP CHRG PUMPS A TROUBLE CHRG PUMPS B TROUBLE BORIC ACID BATCHINGTANK LOWLEVEL CHRG PUMPS A TRIP OR CLOSE CKTTROUBLE CHRG PUMPS 8 TRIP OR CLOSE CKTTROUBLE BORIC ACID TOTALMAKEUP BORIC ACID TANK WATER FLOW AUTOMAKE-UP HIGH-LOWLEVEL DEVIATION SIGNAL BLOCKED CHRG PUMPS A BOTH BKRS IN CHRG PUMPS B BOTH BKRS IN BORIC ACID TANK LOWLOWLEVEL BORICACID FLOW DEVIATION PRESSURIZER AUXSPRAY VLV FULLOPEN BORIC ACID TANK EMPlY COMPUTER ALARM CHARGING SYSlEMS

verload Protection Operation

~ Procedures correctly sequence installation of spare pumps to prevent simultaneous breaker racking' Technical Specification prohibits racking in two CCW pump breakers to a single bus

~ No known incidents involving CCW

~ One incident involving CSIP occurred during 1989 but was promptly identified and corrected

~ Operators aware of potential for overload o Annunciator response procedures provide corrective action

Gverload Protection Missin Interlock Root Cause

~ Failure to reconcile plant design with FSAR 6 Corrective Actions

~ 10CFR60.69 evaluation completed for plant without interlocks

~ Clearance tags installed for additional warning

~ Operating procedures enhanced to provide additional caution

~ Mechanical interlocks will be installed for CSIP and CCW prior to start up from Spring 1997 outage

~ Continue FSAR Improvement Plan

Overload Protection Safet Si nificance o No adverse effect on diesel e No instances found where two CCW pumps were racked in on the same bus simultaneously 6 One instance found where two CSIP. pumps were racked in simultaneously

~ Alarm functioned, operators promptly recognized and corrected

~ Verified compliance with applicable Technical Specification action statement

rain e ara ion

Train or Division Separation Desi n Features o Independent power supplies from each train o Only one breaker provided for each spare pump motor o Unique cubicle/breaker track arrangement o Kirkkey interlocks

Train Separation Spare GubiclelBreaker Track Arrangement

rain eparation Kirk Ke Interlocks o 6.9KV breaker vendor drawings show kirk keys for spare cubicles only I For dual breaker arrangement Kirk keys could have provided interlock to maintain train separation o Kirk keys not properly installed I Confusion regarding purpose of Kirk keys

Train or Division Separation KirkKe Interlocks continued o 1986 PCR initiated to remove kirk keys from "G" breaker cubicles because mechanical provision on breaker modules prevented use of unauthorized breakers.

e PCR voided in 1993 because kirk keys had been abandoned in place o 1994 ESR Engineering Reply recommended removal of kirk keys because no plant drawing or specification was located that described them e Kirkkeys removed from 4 spare cubicles in.1995 by work order

Train eparation Kirk Key removal without 50.59 evaluation

~ Root Cause

~ Responsible engineer did not identify impacted design drawings o Corrective Actions

~ 10CFR50;59 evaluation completed

~ Assessment of past Engineering Reply type ESRs to determine extent of inappropriate usage to be completed

~ Training of appropriate staff personnel to emphasize requirements of 10CFR50.59 evaluation arid restrictions on use of engineering dispositions to be completed

Train eparation Safet Si nificance

~ Multiple design provisions for train or division separation o Design requirements for train separation preserved

Apparent Violation o 1

FR50.5 Two Examples

~ Interlock to prevent overload of emergency power supply by an automatic starting signal for the spare and dedicated CCW pump is not installed as described in the FSAR o Kirkkey interlocks for safety-related breakers were removed without performing a 10CFR50.59 evaluation

Missed Opportunities e Two pre-licensing systematic FSAR reviews

~ Interlock description not in electrical section of FSAR o Start-up testing

~ Alarm tested. as interlock o IE Information Notice 86-79 e 1989 Operational Event

~ Inadequate review of FSAR o Kirk Key Removal

~ Inadequate review of FSAR

pro.

o. 1W080-P-02 I~ Iues Rsv.

1 Initials/Date 6'.19 Verify that the following actions occur:

a.

The red breaker status "CLOSE" light is EXTINGUISHED and the green breaker status "OPEN" light is lit on CS-941 'SA on the ACP.

b; 1

The mechanical indicator on the breaker ind'tes'that the breaker is "OPEN".

a I+~~

6.5.20

~

~

Actuate the folloving transfer switches to the NORM

posxtxon, at Transfer Panel 1A.

(See NOTE preceding St 2).

a.

43T-31/SA b.

43T-5/NA 6.5.21 Return the D.C. pover supply to Transfer Panel 1A to the "AS FOUND" condition of Step 6 ~5elo a.

CKT f37 at 125VDC Panel DP-1A-SA b.

CKT f7 at 125VDC Panel DP-1A-1 NOTE:

The following controls will be performed at the M

6.6 The following steps verify the interlock that produces an alarm if tvo breakers are installed in the same Safety Train.

6.6. 1 Actuate the "COMPONENT COOLING MATER PUMP lA-SA" switch

~

(CS-941.1SA) on the MCB to the "START" positi 6.6.2 Verify that the action.above closes the break 6.6.3 Remove the Truck Operated Cell (TOC) springs in the 6.9KV Emerg.

Bus 1A"SA Cubicle 3 (i.e., the cubicle corresponding to the A-Train feed of CCWP 1C"SAB).

6.6.4 Verify that the "CCW PUMPS A BOTH BKRS IN" ALB

, window 7"5A, annunciates at the MCB.

Vol. V

FSAR Improvement Program Introduction I Identified need for improvement in late 1995, early 1996 o Initiated improvement plan in early 1996 I Effort has been effective in finding issues requiring resolution

~ NRC investigation for apparent violation resulted from a condition report written by plant staff

F AR Improvement Pro ram o Self-assessment showed need for improvement o Presented to NRC on May 30, 1996 o Implemented prior to finding CCW and CSIP interlock deficiency e Three part program:

~ Routine use expected

~ Initial review

~ Selected detailed reviews

F AR Improvement Program Routine Use Expected

~ Reinforce staff's knowledge of purpose and content o FSAR trainirig for technical staff in progress o FSAR to be incorporated into training programs

~ Ownership of individual sections of FSAR o Infrequent evolutions o Outage planning

F AR Improvement Pro ram Initial Review o Performed by knowledgeable individuals, e.g.

~ System Engineers, E8 RC, Nuclear Fuels

~ Operations, Training o Resolve questionable information

~ Other documents as required

~ Field verification as required

~ Resolve in a timely manner o Not a complete validation

~ Scheduled for completion in mid-1997

F AR Im rovement Pro ram Selected Detailed Reviews

~ Selected detailed reviews or validations will be performed

~ Intended to provide in-depth evaluation of selected system or section o Reviews currently planned:

~ SSFI of Reactor Protection System in late 1996

~ Fire Protection in 1997

FSAR Improvement Program Review Results o As of August 20

~ approximately 46'lo complete

~ approximately 156 condition reports issued in 1996

. o Examples identified

~ Pressurizer PORV Alarms

~ ESW Low-Level Alarms

~ Chlorine Detection Equipment

~ Large Break LOCA Analysis Changes o Identified issues have been or are being resolved

Ummary o Minimal safety significance considering operational history e FSAR review continuing o Promptly address discrepancies identified by corrective action program and 10CFR60.59