05000400/LER-2010-003, For Harris, Unit 1, Regarding Condition Prohibited by Technical Specifications When Non-Seismic System Was Aligned to Refueling Water Storage Tank
| ML103270052 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/15/2010 |
| From: | Henderson K Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| HNP-10-127 LER 10-003-00 | |
| Download: ML103270052 (4) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
| 4002010003R00 - NRC Website | |
text
Progress Energy Serial:
NOV 1 5 2010 10 CFR 50.73 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 LICENSEE EVENT REPORT 2010-003-00 Ladies and Gentlemen:
The enclosed Licensee Event Report (LER) 2010-003-00 is submitted in accordance with 10 CFR 50.73, paragraph (a)(2)(i)(B), any operation or condition which was prohibited by the plant's Technical Specification. This report describes an event in which the plant operated under a Technical Specification prohibited condition by exceeding the Allowed Completion Time for an Inoperable Refueling Water Storage Tank. In accordance with 10 CFR 50.73(a) requirements, this LER is submitted within 60 days following the event.
This document contains no new Regulatory Commitments.
Please refer any questions regarding this submittal to Mr. John Caves, Supervisor -
Licensing/Regulatory Programs, at (919) 362-3137.
Sincerely, Kelvin Henderson Plant General Manager Harris Nuclear Plant KH/kab Enclosure cc:
Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Mrs. B. L. Mozafari, NRC Project Manager, HNP Mr. L. A. Reyes, NRC Regional Administrator, Region II Progress Energy Carolinas, Inc.
Harris Nuclear Plant P. 0 l.
Box 165 New Hill, NC 27562 Oaf-
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NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 10/31/2013 (10-2010)
, the NRC may digits/characters for each block) not conduct or sponsor, and a person is not required to respond to, the dinformation collection.
- 3. PAGE Harris Nuclear Plant-Unit 1 05000 0400 1
OF
- 4. TITLE Condition prohibited by Technical Specifications when non-seismic system was aligned to Refueling Water Storage Tank YEAR SEQUENTIA YEAR NUMBER FACILITY NAME DOCKET NUMBER N/A 05000 FACILITY NAME 09 16 2010 2010 003 -
00 N/A DOCKET NUMBER 05000
- 9. OPERATING MODE I
- 10. POWER LEVEL 100
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: (Check all that apply)
LI 20.2201(b)
LI 20.2203(a)(3)(i)
[
50.73(a)(2)(i)(C)
I]
50.73(a)(2)(vii)
[= 20.2201(d) 20.2203(a)(3)(ii)
[
50.73(a)(2)(ii)(A) 50.73(a)(2)(viii)(A)
El 20.2203(a)(1) 20.2203(a)(4)
[]
50.73(a)(2)(ii)(B) 50.73(a)(2)(viii)(B)
[
20.2203(a)(2)(i) 50.36(c)(1)(i)(A)
[
50.73(a)(2)(iii) 50.73(a)(2)(ix)(A)
E] 20.2203(a)(2)(ii) 50.36(c)(1)(ii)(A)
[
50.73(a)(2)(iv)(A) 50.73(a)(2)(x)
E] 20.2203(a)(2)(iii)
[
50.36(c)(2)
[
50.73(a)(2)(v)(A)
E] 73.71(a)(4)
E] 20.2203(a)(2)(iv) 50.46(a)(3)(ii)
E] 50.73(a)(2)(v)(B) nl 73.71(a)(5)
[]
20.2203(a)(2)(v) 5 50.73(a)(2)(i)(A) 5 50.73(a)(2)(v)(C)
E] OTHER E] 20.2203(a)(2)(vi) 50.73(a)(2)(i)(B)
[] 50.73(a)(2)(v)(D)
Specify in Abstract below or in NEI 96-07 Revision I states: Although this criterion allows minimal increases, licensees must still meet applicable regulatory requirements and other acceptance criteria to which they are committed (such as contained in regulatory guides and nationally recognized industry consensus standards, e.g., the ASME B&PV Code and IEEE standards). Further, departures from the design, fabrication, construction, testing and performance standards as outlined in the General Design Criteria (Appendix A to 10 CFR 50) are not compatible with a "no more than minimal increase" standard.
Because the RWST is required to be seismically-qualified, opening 1CT-23 to connect the Fuel Pool Purification System (non-seismic) to the RWST resulted in a deviation from GDC 2. The change should have been considered "more than a minimal increase" which requires prior NRC approval to perform the activity.
CORRECTIVE ACTIONS
Immediate Corrective Actions Revised procedure OP-116.1, Fuel Pool Purification System, to remove the capability to purify the RWST in Modes 1-4.
Actions to Prevent Recurrence Clarify procedural guidance regarding the impact of proposed activities on the design and licensing bases.
PREVIOUS SIMILAR EVENTS
On August 1, 1996, HNP personnel identified, via a review of industry operating experience, a "condition outside the design basis". This condition was that the RWST had been connected to non-seismically qualified piping (non-seismic piping under consideration was the purification system piping and piping leading to the hydrostatic test pump). HNP reported this event to the NRC in Licensee Event Report (LER) 96-13. The cause of this LER was determined to be a failure to reconcile operating procedure lineups with the plant design basis during original procedure development. Corrective actions from that LER included placing administrative controls on 1CT-23 by locally verifying ICT-23 shut as an immediate action and ensuring procedure requirements do not permit opening without declaring the LCO. In 2006, HNP staff concluded that subsequent changes to the industry 50.59 process under NEI 96-07 provided additional flexibility such that prior NRC approval for the activity was no longer needed. This error resulted in not entering the Technical Specification Limiting Condition for Operation action statemtent during the purification activity, which is a condition not allowed by Technical Specifications and requires this Licensee Event Report in accordance with 10 CFR 50.73(a)(2)(i)(B).