ML18005A256
| ML18005A256 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/15/1988 |
| From: | Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A255 | List: |
| References | |
| 50-400-87-38, NUDOCS 8801250536 | |
| Download: ML18005A256 (4) | |
Text
ENCLOSURE 1
NOTICE OF VIOLATION Carolina Power and Light Company Harris Docket No. 50-400 License No.
NPF-63 During the Nuclear Regulatory Commission (NRC) inspection conducted on October 19-23 through November 2-6, 1987, violations of NRC requirements were identified.
The violations involved failure to provide adequate design input documentation and implementing instruction, and failure to follow procedure.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
( 1986),
the violations are listed below:
10 CFR 50, Appendix B, Criterion III, and the licensee's accepted Quality Assurance (QA) program
( Final Safety Analysis Report Section 17.2.3) collectively require that appropriate quality standards are specified and included in design documents.
The licensee is committed to Regulatory Guide 1.64 Quality Assurance Requirements for the Design of Nuclear Power Plants which endorses ANSI N45.2. 11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants.
1.
Section
- 3. 1 of this standard states that applicable design inputs shall be identified, documented, and their selection reviewed and approved and that the design input shall be specified to the level of detail necessary to provide a consistent basis for accomplishing design verification measures.
Contrary to the above, design inputs for design change
- packages, PCR 2292 identifying circuit board schematics and PCR 1286 identifying system design pressures, were not formally identified, specifically
- approved, nor presented in necessary detail to provide a consi stent basis for design verification measures.
These examples are not intended to be all inclusive.
2.
Section
- 4. 1 of this standard states that design activities shall be prescribed and accomplished in accordance with procedures of a
type sufficient to assure that applicable design inputs are correctly translated into specifications,
- drawings, procedures or instructions.
Contrary to the above, design activities for design change
- packages, PCR 2292 did not provide adequate detail of protective and control functions for fuse removal and PCR 1391 did not provide adequate detail for setting struts to within +1 degree, and +1.5 degrees.
Design activities were not prescribed and accomplished with sufficient detail to ensure that the applicable design inputs would be correctly translated into adequate procedures or instructions.
This is a Severity Level IV violation (Supplement I).
880i250536 880ii5 PDR ADOCK 05000400
Carolina Power and Light Company Harris Docket No. 50-400 License No.
NPF-63 B.
10 CFR 50, Appendix B. Criterion V, and the licensee's accepted QA program (FSAR Section 17.2.5) collectively require that activities affecting quality shall be prescribed by documented instructions, procedures, or
'rawings and shall be accomplished in accordance with those instructions, procedures, or drawings.
1.
Maintenance Surveillance Test (MST)
- M0016, Emergency Diesel Generator Fuel Injection Nozzle Inspection and Cleaning, Revision 1,
dated October 22, 1987, requires that:
(4.2. 1) "All procedure steps normally shall be performed in sequence.
If a change in sequence for a particular job is needed or desired, the maintenance foreman or his designee will approve and the lead craftsman will annotate the field copy of the procedure to show the new sequence.
Depending on the conditions which warranted the change, the lead craftsman should consider submitting a
maintenance feedback report (FBR) for a
procedure revision."
Contrary to the
- above, while performing MTS-M0016 on both the A 6 B
train of the diesel generator several steps of the test were not performed and were not properly documented.
2.
Administrative Procedure (AP)
AP-007, Revision 5,
Temporary and Advance Changes to Plant Procedures, dated June 6,
1987, requires that:
(5. 1) temporary changes are to be used to correct procedures when the changes do not affect the intent of the original procedure.
Examples of appropriate use for temporary changes are:
A plant condition or mode temporarily devi ates from that for which the procedure would normally be used.
An error or omission needs to be corrected in order to use the procedure.
Contrary to the above, while performing Engineering Surveillance Test Procedure (EST) 204, Reactor Coolant System Isolation Valve Test, on July 21,
- 1987, changes to the procedure were accomplished without obtaining proper approval.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a wr>tten statement or expla'nation in reply including (for each violation):
( 1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results
- achieved, (4) the corrective steps which will
Carolina Power and Light Company Harris Docket No. 50-400 License No.
NPF-63 be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is
- shown, consideration will be given to extending the response time.
r FOR THE NUCLEAR REGULATORY COMMISSION
)p~
v'audle A. Julian, Chief Operations Branch Division of Reactor Safety Dated at Atlanta, Georgia this
].5th dav of January 1988
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