ML18004B904
| ML18004B904 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/21/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-573 HO-870483-(O), NUDOCS 8708250227 | |
| Download: ML18004B904 (8) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR: 8708250227 DOC. DATE: 87/08/21 NOTARIZED:
NO FACIL: 50-400 Shear on Harris Nuclear Power Plant>
Unit 1I Carolina AUTH. NAME AUTHOR AFFILIATION WATSONI R. A.
Carolina Power 5 Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 870722 ltr re violations noted in Insp Rept 50-400/87-20. Corrective actions: safety evaluation reperformed for PCR 1286 documenting adequate bases For determining that changes did not pose unreviewed question.
DISTRIBUTION CODE:
IEOID COPIEB RECEIVED: LTR J ENCL J.
SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit renewal filed.
DOCKET ¹ 05000400 05000400 REC IP IENT ID CODE/NAME PD2-1 PD COPIES LTTR ENCL 1
1 RECIPIENT ID CODE/NAME BUCKLEY'S B COPIES LTTR ENCL 2
2 INTERNAL:
AEOD NRR MORISSE*UI D NRR/DREP/EPB NRR/DRIS DIR OE ER MANIJ
~ED PP IiiEE)
FILE 01 EXTERNAL:
LPDR NSIC 1
1 1
1 1
1 1
1 1
1 1
1 1
1 DEDRO NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ILRB OGC/HDS1 RES DEPY GI 1
1 NRC PDR 1
1 1
1 1
1 2
2 1
1 1
1 1
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 20
CARL Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, NC 27562 AUG 2$
1987 File Number'SHF/10-13510E Letter Number'HO-870483 (0)
NRC-573 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:
In reference to your letter of July 22, 1987, referring to I.E.
Report RII:
50-400/87-20, the attached is Carolina Power
& Light Company's reply to the violation identified in Enclosure l.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very. truly yours, R. A. Watson Vice President Harris Nuclear Project
.-RAW:ddl Attachment cc'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 87O82>< ~~
gOPO400 870821 PDR ADOCK P PDR 6
MEM/HO-8704830/PAGE 1/Osl
Attachment to CPRL Letter of Response to NRC I.E. Report RII:
50-400/87-20 Re orted Violation.'0 CFR 50.59 states that the licensee may make changes to the facility without prior Commission approval unless the proposed change involves an unreviewed safety question.
It further states that a proposed change shall be deemed to involve an unreviewed safety question if the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously. evaluated in the safety analysis report may be increased.
It also states that the licensee shall maintain records of change in the facility and that these records shall include a written safety evaluation which provides the bases for determining that the change does not involve an unreviewed safety question.
Contrary to the above, although safety evaluations were prepared for Plant Change Request (modification,, PCR) 1286 and PCR 825, neither safety evaluation adequately provided the bases to assure that the consequences of an accident previously evaluated in the safety analysis report may be increased.
This is a Severity Level V violation (Supplement*1).
Denial or Admission and Reason for The Violation.'he violation is correct as stated.
On July 31,
- 1987, a panel was assembled to provide review of safety reviews, determine the cause of the problem and develop appropriate corrective actions.
This panel consisted of a Technical Support Engineering Supervisor and engineers from On-Site Nuclear Safety, Corporate Nuclear Safety, Site Engineering, Technical Support and Corporate Engineering.
The panel's findings were that the safety review process did not properly document, for modifications, the facts,and logic required to support the conclusions made in the evaluation.
In particular, the format of the safety review checklist did not provide adequate guidance to ensure that bases for making each determination was properly documented.
As a result, the level of documentation for modifications was below what CP6L now considers acceptable and the safety reviews performed for PCR 1286 and PCR 825 did not document adequate bases.
However, in all cases, from this review, the conclusion of the panel were consistent with those of the original reviewers that no unreviewed safety questions exist.
MEM/HO-8704830/PAGE 2/Osl
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Corrective Ste s Taken and Results Achieved:
The safety evaluation was reperformed for PCR 1286 documenting adequate bases for determining that the changes did not pose an unreviewed safety question.
The safety evaluation for PCR 825 is in the process of being reperformed to document adequate bases and completion is expected by October 1,
1987.
It should be noted that the purpose of PCR 825 was to evaluate not performing a
modification, thrust spring removal from the Auxiliary Feedwater (AFW) Pumps, until a later date.
Subsequently, the spring removal modification was accomplished; therefore, the task of reperforming the safety evaluation for PCR 825 does not pose a question of the equipment's operability, but is a documentation backfit.
Corrective Ste s Taken to Avoid Further Noncom liance.
On July 29, 1987, site management suspended the installation of any new modifications, until appropriate corrective action could be taken to preclude further occurrences.
The panel described above has reviewed over 100 safety evaluations and has taken corrective actions to correct inadequate documentation of bases statements, such as, accept-as-is, reperform by panel, or return to original safety reviewer to reperform.
In all cases, from this review, the conclusion of the panel were consistent with those of the original reviewers that no unreviewed safety questions exist.
The panel concluded that inadequate documentation of bases statements did exist.
Based on these reviews and the new safety reviews performed by the panel, changes to the safety review procedure and training aids were developed.
Procedure AP-011 was revised on August 7, 1987.
Supplemental training was completed August 10, 1987 using lessons learned and new training aids were
,given to safety reviewers that perform reviews on design changes.
The personnel that have received the supplemental training have been identified on the qualified safety reviewer list to denote only those persons qualified to do design change safety reviews.
Safety evaluations for the remaining PCRs will be reviewed by the panel to confirm that no unreviewed safety questions exist.
This review of remaining PCRs is expected to be completed by November 1,
1987. If a potential unreviewed safety question is identified, the matter will be submitted to the Plant Nuclear Safety Committee (PNSC) for resolution.
Inadequate documentation of bases statements identified during this review will also be corrected.
MEM/HO"8704830/PAGE 3/Osl
0
Until the return rate is acceptably low, the panel will continue to review design change safety reviews to judge acceptability and provide feed. back to the originator.
When an acceptable rate is
- achieved, the review responsibility will again be borne by the plant supervisors and managers.
Date When Full Com liance Will. Be Achieved:
The following items require completion before full compliance is achieved:
1.
Reperform safety evaluation for PCR 825 (completion by October 1, 1987).
2.
Complete review of remaining PCRs safety evaluations to determine if unreviewed safety question exists (completion=by November 1, 1987).
3.
Correct inadequate documentation of bases statements identified during review of remaining PCR's safety evaluations (completion by April 30, 1988).
MEM/HO"8704830/PAGE 4/Osl
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