ML18005A289
| ML18005A289 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/12/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-605 HO-880027-(O), NUDOCS 8802160199 | |
| Download: ML18005A289 (7) | |
Text
REGULATORY I NFQRi }ATION D ISTR IBUTI QN SYSTEN
( R I DS )
ACCESSION NBR: 8802160199 DOC. DATE: 88/02/12 NOTARIZED:
NO FACIL: 50-400 Shearon Harv is Nucleav Poeer Planti Unit 1I Cavolina AUTH. NAME AUTHOR AFFILIATION IrjATSONI R. A.
Carolina Poeer
'c Light Co.
RECIP. NANE RECIPIENT AFFILIATION Document Contv ol Branch (Document Contv ol Desk)
SUBJECT:
Responds to NRC 880115 ltr re violations noted in Insp Rept 50-400/87-38.
Cov v ective ac tions: data sheets completed as required to indicate that inspector orifice measuv ements not taken during performance of test.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR i
ENCL I
SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response DOC )'.ET 05000400 NOTES: Application for permit v eneuJal filed.
05000400 I
RECIPIENT ID CODE/MANE PD2-1 PD INTERNAL:
AEOD NRR i IOR ISSEAUz D NRR/DLPG/G*9 NRR/DREP/EPB NRR/DRIS DIR QE E'BER N> J RGN2 FILE 01 EXTERNAL:
LPDR NS IC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 REC IP IENT ID CODE/NANE BUCKLEY. B DEDRO NRR/DLPG/PEB NRR/DOEA DIR NRR/DREP/RPB NRR/PNAS/ ILRB OGC/HDS1 RES/DRPS DIR NRC PDR COPIES LTTR ENCL 2
2 1
1 1
1 1
2 2
1 1
1 1
1 1
TOTAL NUNBER OF CQP IES REQUIRED:
LTTR 22 ENCL 22
Carolina Power
& Light Company HARRIS NUCLEAR PROJECT P. O.
Box 165 New Hill, North Carolina 27562
.FEB t2 1988 File Number:
SHF/10"13510E Letter Number'H0-880027 (0)
NRC-605 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen.'n reference to your letter of January 15,
- 1988, referring to I.E. Report RII:
50-400/87-38, the attached is Carolina Power 6
Light Company's reply to violation "B" identified in Enclosure 1.
It is considered that the corrective actions taken 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 Plant MGW:mdt Attachment cc'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 0~1~0>99 8802k+
ADO<K 05000400 8
PDR MEM/HO-8800270/Page 1/OS1
Attachment to CP&L Letter of
Response
to NRC I.E.
Report RII:
50-400/87-38 Violation "B" Re orted Violation'.
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 drawings and shall'e 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 MST-M0016 on both the A & 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 deviates 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).
MEM/HO-8800270/Page 2/OS1
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
1.
The violation occurred because the two mechanics who performed MST-M0016 were not aware of the documentation requirements relative to the omission of steps in the procedure.
The intent of performing MST-M0016 did not include that the injector orifice measurements be taken at this
- time, therefore, the associated steps were omitted during the performance of the test, yet the omission was not documented as required by section 4.2.1 of MST-M0016.
2.
The individual responsible for the subject changes to EST-204 was not aware that providing additional direction in the procedure without initiating a temporary or advance change was in violation of AP-007.
Corrective Ste s Taken and Results Achieved:
1.
The subject MST-M0016 data sheets were completed as required to indicate that the injector orifice measurements were not taken during performance of the test.
The deferral of taking the injector orifice measurements was concurred with by the vendor.
No instances of recording test data for portions of the test not performed were noted.
2.
The responsibility for performance of the Reactor Coolant System Isolation Valve Testing has been transferred from the Technical Support group to the Operations group.
EST-204 has been superceded by OST-1506 and the subject changes have been incorporated as deemed necessary.
Corrective Ste s Taken To Avoid Further Violations:
1.
The two maintenance personnel involved were specifically counseled regarding the incident.
Appropriate maintenance personnel have been reminded of the necessity for strict adherence to procedures.
2.
Appropriate personnel have been reminded on the requirements of., AP-007, specifically that if a change which provides any degree of
. direction in performance of the procedure is
- desired, a temporary or advance change shall be initiated in accordance with AP-007.
Date When Full Com liance Was Achieved:
Full compliance was achieved on February 12,
- 1988, upon completion of the actions taken as described above.
MEM/HO"8800270/Page 3/OS1