ML18022A634
| ML18022A634 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/29/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-618 HO-880096-(O), NUDOCS 8805030288 | |
| Download: ML18022A634 (5) | |
Text
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ACCESSION NBR FAC IL: 50-400 AUTH. NAME W*TSONI R. A.
REC IP. NAME REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) 8805030288 DOC. DATE: 88/04/2V NOTARIZED:
NO Shearon Harris Nuclear PouJer Plant1 Unit 1 i Carolina AUTHOR, AFFILIATION Car o1ina Poeer
~~ Ligh Co.
REC IP IENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 0500040C
SUBJECT:
Responds to NPC 880401 ltr re violations noted in Insp Rept 50-400/88-OE>. Corrective actions: 871216 change to Procedur e
EOP-EPP-010 5 880106 change to Procedure EOP-EPP-003 issued changes made re control of plant design chahges.
DISTRIBUTiON CODE:
IEOID COPIES RECEIVED: LTR t
ENCL j SIZE:
TITLE:
t eneral
<50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit reneeal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS DEDRQ NRR/DLPG/PEB 11 NRR/DQEA D IR 11 NRR/DREP/RP8 f0 NRR /P MAS/ILRB12 OGC 15-B-18 RES/DRPS DIR FXTERNAL:
LPDR NSIC COPIES LTTR ENCL 1
1 2
2 1
1 1
1 2
2 1
1 f
1 1
1 1
1 1
RECIPIENT ID CODE/NAME 13UCKLEYr B AEQD NRR MORISSEAUi D NRR/DLPG/GAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A E
RMANi J
-L 02 RGN2 FILE 01 NRC PDR CQP IES LTTR ENCL 1
1 1
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1 1
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
C~L Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, North Carolina 27562 APR Z9 )g88 File Number'SHF/10-13510E Letter Number'HO-880096 (0)
NRC-618 Document Control Desk 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 April 1, 1988, referring to I.E.
Report RII:
50-400/88-06, the attached is Carolina Power
& Light Company's reply to the violation identified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours,
~~J~m~
R. A. Watson Vice President Harris Nuclear Project MGW:dj Attachment cc.'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC)
S8050/QPg8 880//
Q ADOCK 05000400 PDR MEM/HO-8800960/Page 1/OS1
Attachment to CP6L Letter of Response to NRC I.E. Report RII:
50-400/88-06 Violation Re orted Violation:
Technical Specification 6.8.1a requires that written procedures be implemented covering the procedures outlined in Appendix A of Regulatory Guide 1.33, Rev.
2, February 1978.
Administrative Procedures are identified in Appendix A of the Regulatory Guide.
An Administrative Procedure titled "Procedure Review and Approval,"
- AP-006, Rev.
7, Sections 5.7 and 5.8, requires that Emergency Operating Procedures must be technically accurate to safely perform their intended function.
Contrary to the
- above, from September 24,
- 1986, until December 10,
- 1987, AP"006 was not implemented in that an Emergency Operating Procedure EOP-EPP-010, titled "Transfer to Cold Leg Recirculation" was not revised to include the valve configuration described in FSAR Table 6.3.2-6.
Failure to revise the EOP to ensure that a single RHR pump would perform its intended function while operating in the recirculation configuration could have resulted in a total loss of RHR during a
LOCA condition.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for The Violation'.
The violation is correct as stated.
In September 1985 and August
- 1986, Westinghouse recommended changes to the procedure described in FSAR Table 6.3.2-6 for the transfer of the Emergency Core Cooling System (ECCS) from the injection to the recirculation phase.
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 Residual Heat Removal Pump (RHRP) to supply both Charging Safety Injection Pumps (CSIPs).
These proposed changes were approved for implementation at SHNPP.
An FSAR change (serial HPOS-845) was initiated to incorporate these changes.
As part of the review of these
- changes, the on-site Technical Support Unit 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 MEM/HO-8800960/Page 2/OS1
was created.
(It was subsequently demonstrated that with this revised lineup 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.
This change was not incorporated into EOP-EPP-010 as required.
There is no single reason as to why 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.
Corrective Ste s Taken and Results Achieved:
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, a change to 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.
MEM/HO-8800960/Page 3/OS1
Corrective Ste s Taken to Avoid Further Noncom liancce'.
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.
These changes are considered sufficient to preclude further noncompliance.
~
Changes to the plant components which require a Plant Change Request (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 have been taken'.
~
Changes to the FSAR approved in 1986 have been verify that those changes which alter procedures the FSAR were properly implemented in the plant.
situations were discovered.
reviewed to described in No similar
~ 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.
Date When Full Com liance Was Achieved:
Full compliance was achieved on February 9, 1988.
MEM/HO-8800960/Page 4/OS1