ML18012A353

LER 96-013-00:on 960801,operations Personnel Identified Condition Outside Plant Design Basis Where RWST Had Been Connected to Nonseismically Qualified Sys.Caused by Failure to Reconcile Operation procedure.W/960830 Ltr

ML18012A353
Person / Time
Site:	Harris
Issue date:	09/03/1996
From:	Donahue J, Johnny Eads CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-96-146, LER-96-013, LER-96-13, NUDOCS 9609170380
Download: ML18012A353 (5)

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) k ACCESSION NBR:9609170380 DOC.DATE: 96/09/03 NOTARIZED: NO DOCKET I FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION EADS I J. Carolina Power & Light Co.

DONAHUE,J.W. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

LER 96-013-00:on 960801,operations personnel identified condition outside plant design basis where RWST had been connected to nonseismically qualified sys.Caused by failure to reconcile operation procedure.W/960830 ltr.

DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.

NOTES:Application for permit renewal filed. osooo4oo G RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 LE,N 1 1 INTERNAL: ACRS 1 1 AEOD SPD RAB 2 2 AEOD/SPD/RRAB 1 1 LE CEN R~ 1 1 NRR/DE/ECGB 1 1 NRR DE EELB 1 1 NRR/DE/EMEB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DRCH/HQMB 1 1 NRR/DRPM/PECB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 D RES/DSIR/EIB 1 1 RGN2 FILE 01 1 1 EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 2 2 NOAC MURPHY,G.A 1 1 NOAC POORE,W. 1 1 NRC PDR 1 1 NUDOCS FULL TXT 1 1 N

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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

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Carolina Power & Light Company Harris Nuclear Plant PO Box 165 New Hill NC 27562 AUG 3 0 1996 U.S. Nuclear Regulatory Commission Serial: HNP-96-146 ATTN: NRC Document Control Desk 10CFR50. 73 Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 LICENSEE EVENT REPORT 96-013-00

Dear Sir or Madam:

In accordance with Title 10 to the Code of Federal Regulations, the enclosed Licensee Event Report is submitted. This report concerns a condition outside of the design basis where the Refueling Water Storage Tank (RWST) had been connected to a non-seismically qualified system.

Sincerely, J. W. Donahue Director of Site Operations Harris Plant JHE/jhe Enclosure c: Mr. J. B. Brady (NRC - HNP)

Mr. S. D. Ebneter (NRC - RII)

Mr. N. B. Le (NRC - PM/NRR) 9609I70380 960903 PDR ADOCK 05000400 PDR State Road 1134 New Hill NC

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150.0104 l495) EXPIRES 04/30/98 ESTIMATED BURDEN PER RESPONSE'O COMPLY W(TH THIS MANDATORY (NFORMAT(ON COLIECTION REDDEST: 500 HRS. REPORTED lESSONS LEARNED ARE LICENSEE EVENT REPORT (LER) INCORPORATED INTO THE LICENSING PROCESS ANO FED BACK TO (NOUSTRZ.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE (NFORMATION AND RECORDS MANAGEMENT BRANCH IT B f33L US. NUCIEAR REGULATORY COMMISSION, (See reverse for required number of WASHU(GTOM, OC 20555000l, ANO TO THE PAPERWORK REDUCT(ON PROJECT (3150.

digits/characters for each block) 0(0(L OFf(CE OF MANAGEMENT AND BUDGET, WASHU(GTON. OC 20503.

FACILITY NAME (1( DOCKET NUMBER (2( PAGE (3I Harris Nuclear Plant Unit-1 50-400 1OF3 TITLE (4(

Condition outside of design basis where the RWST had been connected to a non-seismically qualified system.

EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (6)

FACIUTY NAME DOCKET NUMBER SEQUENTIAL REVISION MONTH OAY YEAR YEAR MONTH OAY YEAR NUMBER NUMBER 05000 FACILITY NAME DOCKET NUMBER 08 01 96 96 013 00 09 03 96 05000 OPERATING THIS REPORT IS SUBMITTED PUR SUANT TO THE REQUIREMENTS OF 10 CFR Et (Check one or more) (11)

MODE (9) 20.2201(b) 20.2203(a)(2)(v) 50 73(a)(2)(l) 50.73(a) (2) (vill) 20.2203(a)(1) 20.2203(B) (3) (i) X 50.73(a)(2)(ii) 50.73(B)(2)(x)

POWER 1ooo LEVEL (10) 20.2203(a) (2) (I) 20 2203(a)(3)(ll) 50.73(a)(2)(iii) 73.71 20.2203(B) (2) (H) 20.2203(B)(4) 50.73(a) (2) (iv) OTHER 20.2203(B)(2)(iii) 50.36(c)(1) 50.73(a)(2)(v) Speofy ln Abstract below or In NRC Form 366A 20.2203(a) (2) (iv) 50.36(c) (2) 50.73(a)(2)(vll)

LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (Iocrvcc Arcs Cocci Johnny Eads Project Engineer - Licensing (91 9) 362-2646 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

REPORTABLE REPORTABLE CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER TO NPROS TO NPROS

...,,IA rss SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH OAY YEAR YES SUBMISSION (If yes, complete EXPECTED SUBMISSION DATE). X No DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On August 1, 1996 with the plant operating in Mode-1 at 100% power, Operations personnel identified a condition outside the plant design basis where the Refueling Water Storage Tank (RWST) had been connected to a non-seismically qualified system. Specifically, non-seismic portions of the fuel pool purification system have been aligned to the RWST for cleanup and non-seismic portions of the hydrostatic test pump have been aligned to the RWST to fill the Safety Injection accumulators. If a seismic event were to occur, the non-seismic portions of these systems could fail and drain the RWST.

This condition was caused by a failure to reconcile operating procedure lineups with the plant design basis during original procedure development. Subsequent technical and safety reviews also failed to identify the conditions as outside the plant design basis.

Immediate corrective actions included establishing administrative controls to maintain the seismic boundary isolation valves closed. Additional corrective actions include a review of other seismic/non-seismic interface boundary valves for similar problems. Long term design and/or operational options for RWST cleanup and hydrostatic test pump operation are being evaluated.

NRC FORM 366A US. NUCEEAR REGUlATORY COMMISSION (495)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACIlITT NAME II) DOCKET lER NUMBER I&) PACE I3)

SEOUENTIAl REVISION YEAR NUMBER NUMBER Shearon Ha))is Nucleai Plant - Unit //1 50400 2 OF 3 96 - 013 - 00 TEXT PF otoro sprtoit trovird, vso rdoFtioorl oopm of NRC Potvt 3ESU i)T)

EVENT DESCRIPTION:

On August 1, 1996 with the plant operating in Mode-1 at 100% power, Operations personnel identified a condition outside the plant design basis where the Refueling Water Storage Tank (RWST) (EIIS Code: BQ - TK) had been connected to a non-seismically qualified system. Specifically, non-seismic portions of the fuel pool purification system (EIIS Code - DA) have been aligned to the RWST for cleanup and non-seismic portions of the hydrostatic test pump (EIIS Code - BP) have been aligned to the RWST to fill the Safety Injection (SI) accumulators. If a seismic event .

were to occur, the non-seismic portions of these systems could fail and drain the RWST. This condition was identified by the Superintendent - Shift Operations while reviewing a recent similar event at Salem.

Fuel Pool Purification Connection The original plant design of the fuel pool purification system was non-safety, non-seismic and separated from the RWST by a normally closed safety related boundary valve. The boundary valve (1CT-23) is manually operated and does not receive an automatic isolation signal. The design basis documents describing the RWST (DBD-106) and the fuel pool purification system (DBD-110) do not describe RWST cleanup during operation. FSAR Section 9.1.3.2 states that the fuel pool purification pumps can take suction from and return fluid to the RWST; however, no operational limitations are discussed. Based on the above, extended use of the fuel pool purification system aligned to the RWST during normal operation was not analyzed.

The original issue of operating procedure OP-116, "Fuel Pool Cooling and Cleanup," (9/4/84) provided for RWST purification using the fuel pool purification system. Procedure reviews and safety reviews were performed, however, they did not identify that this mode of operation would place the system outside its design basis. FSAR Figures 6.2.2-1 and 9.1.3-1 show the seismic/non-seismic boundary. Operations, ALARAand Chemistry reviews were completed but did not question the non-seismic interfaces.

H drostatic Test Pum Connection The original design of the hydrostatic test pump was non-safety, non-seismic and separated from the RWST by a normally closed safety related boundary valve. This boundary valve (1CT-22) is manually operated and does not receive an automatic isolation signal. The hydrostatic test pump design basis document includes a statement that the hydrostatic test pump is isolated from the process piping during normal operation.

The original issue of operating procedure OP-110, "Safety Injection," (9/27/84) did not include valve 1CT-22, however, it did include procedural guidance for filling the SI accumulators with the hydrostatic test pump. Revision 1 (12/24/85) to OP-110 added valve 1CT-22 and directs the operator to unlock and open the valve. Operations and Chemistry reviews were completed for both revisions. The safety evaluation performed in accordance with 10CFR50.59 for Revision 1 states that a common mode failure is not introduced by the performance of this procedure.

FSAR Figures 6.2.2-1 and 6.3.2-3 show the seismic/non-seismic boundary. OP-110 references a Westinghouse Safety Injection System Description which states that the hydrostatic test pump serves no safety related function but permanent connections are provided for using the hydrostatic test pump in supplying borated water for filling and level adjustment of the accumulators. In addition to OP-110, the hydrostatic test pump connection to the RWST is also used during performance of OST-1506, "Reactor Coolant System Isolation Valve Leak Test -.18 Month Interval-Mode 3." OST-1506 is performed to satisfy Technical Specification surveillance requirements 4.0.5 and 4.4.6.2.2.

The procedure reviews and safety reviews for OST-1506 also failed to identify that this mode of operation would place the system outside its design basis.

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LICENSEE EVENT REPORT (LEB)

TEXT CONTINUATION FACILITY NAME II) DOCKET LER NUMBER (6) PAGE Ii)

BEQUENTML REVISNN YEAR NUMBER NUMBER Shearon Harris Nuclear Plant ~ Unit ¹1 50400 3 OF 3 96 - 013 - 00 TEXT lllmove spose N reevved, vse eddRRmol sopis ol ARC funv 3BQI (IT)

CAUSE:

This condition was caused by a failure to reconcile operating procedure lineups with the plant design basis during original procedure development. Subsequent technical and safety reviews also failed to identify the conditions as outside the plant design basis.

SAFETY SIGNIFICANCE:

The RWST is a safety related water source used by multiple safety systems following a design basis accident including charging/safety injection, residual heat removal, and containment spray. The conditional core damage probability (CCDP), given a seismic event of magnitude greater that the operating basis earthquake, was determined to be 7.32E-2, assuming that a reactor trip occurs and that all non-seismically qualified components and systems are unavailable after the event. If the RWST is also assumed to be unavailable after the seismic event, then the CCDP increases to 7.64E-2, a 4.4% increase. The RWST is not typically assumed to be required to mitigate a seismic event, and the small increase in CCDP is due to scenarios involving random failures of secondary side heat removal systems, which result in a demand for bleed-and-feed cooling using the RWST. Simultaneous design basis accidents and earthquakes are highly unlikely and, in accordance with standard industry PRA practices, not evaluated.

This condition is reportable per 10CFR50.73(a)(2)(ii).

PREVIOUS SIMILAR EVENTS:

Similar plant events where non-seismic piping has been temporarily connected to safety related systems during plant operation have included: (1) Post Accident Sampling system connection to the Emergency Service Water system (1989), (2) chemical addition tank connection to the Component Cooling Water system (1994), and (3) chemical addition tank connection to the Essential Services Chilled Water system (1994). Corrective actions for these similar events were narrowly focussed and did not identify the similar problems with RWST connections.

Similar industry events have been identified which involved non-seismic connections to the RWST. These included events at San Onofre (1989), Diablo Canyon (1990), and Salem (1996). The San Onofre event was documented in an NRC Daily Plant Status Report, however this event did not receive a Harris Plant review. No industry operating experience feedback notification of the Diablo Canyon event could be located. As a result, no Harris Plant review was conducted. The recent similar event at Salem was reviewed by the Harris Plant Superintendent - Shift Operations and resulted in this condition being identified at the Harris Plant.

CORRECTIVE ACTIONS COMPLETED:

1. Established administrative controls to maintain the seismic boundary isolation valves closed.

CORRECTIVE ACTIONS PLANNED:

1. Review other seismic/non-seismic interface boundary valves for similar problems by October 31, 1996.

2. Evaluate long term design and/or operational options for RWST cleanup and hydrostatic test pump operation by December 31, 1996.,

5 A(4- )