ML20197A952
| ML20197A952 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/20/1986 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-490 HO-865506-(O), NUDOCS 8610270428 | |
| Download: ML20197A952 (3) | |
Text
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Cp&L Carolina Power & Light Company n6 0C720 A9: 5g o
muso ca.wimwaremmzze:mt HARRIS NUCLEAR PROJECT P.O. Box 165 New Hill, NC 27562 File Number: SHF/10-13510E NRC-490 Letter Number: HO-865506 (0)
Dr. J. Nelson Crace U.S. Nuclear Regulatory Commission Region II 101 Marietta Street NW, Suite 2900 Atlanta, Georgia 30323 Shearon Harris Nuclear Power Plant Unit No. 1 - Docket No. 50-400
SUBJECT:
Emergency Operating Procedures
Dear Dr. Grace:
As part of the Operational Readiness Inspection conducted during the week of Sept. 22 to 26, NRC personnel reviewed the SHNPP Emergency Operating Procedures (EOPS) Rev. 1.
Specific audit findings were given to CP&L on Sept. 26, and our response to their comments was discussed during a phone conversation between Mr. J.
M. Collins of CP&L and Mr. Bruce Wilson of the NRC and forwarded to the NRC by letter.
During our review of the audit comments, CP&L determined that we should review our network relative to the Westinghouse Owners Group (WOC) Emergency Response Guidelines (ERCS). A three member task force comprised of an SRO licensed Shift Technical Advisor (STA) and two SRO contract personnel familiar with both the WOC ERCS and SHNPP E0P network was established to conduct this review. The purpose of this review was to identify areas where the SHNPP E0P network (Rev. 1) differed from the WOC ERGS (Rev. 1) and evaluate the justification of the differences contained in our Step Deviation Document (SDD). This review was conducted during the week of Sept. 29 to Oct. 3.
We evaluated each procedure in the SHNPP E0P network relative to the corresponding guideline in the WOJ ERCS.
Additional justification of differences was incorporated in the Step Deviation Document. In some cases, the original justification for a difference was deemed inappropriate, and a set SHNPP E0P's were modified to restructure the step to be consistent with WOC ERCS.
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Dr. J. Nelson Grace NRC-490 Page 2 These changes were categorized as either a technical change or procedure enhancement. Changes were categorized as procedure enhancements when the current SHNPP step (s) accomplishes the intent of the ERC steps, but the instructions can be changed to provide better clarity. A technical change is one that changes the way we implement the mitigation strategy of the WOC ERCS. The only major technical change that has been identified to date deals with the use of foldouts in the E-0 portion of PATH-1.
SHNPP foldout B currently allows the operator to transit to procedures that deal with isolating a ruptured or faulted SG " earlier" than that allowed by the WOG ERCS.
During multiple failure scenarios, this could result in missing or delaying some steps. SHNPP will revise PATH-1 and its foldouts to be consistent with the guidance contained in the ERCS and their foldouts.
EPP-16, " Steam Generator Tube Rupture Isolation" will be deleted and we will transit to PATH-2 to deal with all SGTRs. PATH-2 and its foldouts will also be revised to reflect the deletion of EPP-16 and to be consistent with the corresponding ERC (E-3) and foldouts. During this review our intent was to return to the WOC structure and content unless a deviation could be technically justified. This review was completed on Oct. 3, 1986.
We are currently reviewing our E0P setpoint study to ensure that all the values used in the E0P's are valid and consistent with the final plant design. This review is being done by two SRO licensed SHNPP STAS and will be completed by Oct. 15th. Any required changes will be included in the December 12th revision of the E0Ps and the next revision to the SDD (to be completed by January 31, 1987).
The SHNPP E0P network is currently undergoing a revision process. A task force has been established to complete this revision by December 12, 1986. The task force is comprised of two l
SRO licensed STAS, one licensed senior control operator, one SRO licensed contractor, and RMS Associates. RMS Associates is a contract group with personnel who have been involved in SHNPP E0P l
development since its inception, and Human Factors experts. The l
revision will include a Human Factor review and upgrade of our l
network, setpoint changes required by the final plant design, and l
incorporation of the results of our review relative to the WOC l
ERC's.
This revision will be completed by Dec. 12, 1986.
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l MEM/H0-8655060/PAGE 2/OSI
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i Dr. J. Nelson Grace NRC-490 Page 3 All procedural changes will be identified and supplied to the Harris Training Unit (HTU) as the procedures are finalized. HTU personnel will review the changes and determine what operator retraining is required to ensure the operating crew can make a smooth transition from the current procedures (Rev. 1) to the future procedures (Rev. 2).
The majority of changes that will be made in the E0P network are procedural enhancements and should not require extensive retraining since the intent of the instructions remains unchanged. Technical changes will be identified and operator training will be explicitly conducted-on these items, setpoint changes, rand general procedural changes as appropriate.
All required retraining will be completed prior to exceeding 5%
power.
Please call Mr. Joe Collins at (919) 362-2088 if you have any further questions.
1 Yours very truly, AWU R. A. Watson Vice President Harris Nuclear Project RPP:cge cc:
Mr. C. Maxwell (NRC SHNPP)
Mr. B. Buckley (NRC) l t
MEM/HO-8655060/ PACE 3/0S1
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