ML18005A290

Responds to NRC 880115 Ltr Re Violations Noted in Insp Rept 50-400/87-38.Corrective actions:MOD-204 Procedure Revised to State,In Part,That Special Installation Instructions Shall Be Specified in Mod Package

ML18005A290
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-604 HO-880026-(O), NUDOCS 8802160256
Download: ML18005A290 (7)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) i.'!

y! ACCESS I QN NI3R 88021 o0256 DOC. DATE: 88/02/12 NOTARIZED: NO DOCKET FACIL; 50-400 Shea'r on Harris Nuclear Power Plant. Unit 1> CaT olina 05000400 AUTH. NAME AUTHOR AFFILIATION IIATSQN> R. A, Carolina Power 4 Light Co.

RECIP. NAME REC IP lENT AFFILIATION Document ContTol Branch (Document Control Desk)

SUBJECT; Responds to NRC SSG115 ltr re violations noted in Insp Rept 50-400/87-88. Core ective actions: MOD-204 procedure revised to state> =n> par t that special instal lation instructions shall be specified in mod package.

DIETRIBUT!OR CODE Ii CID COPIEE RECE!VED: LTR I ENCL I SIZE:

TITLE: C'ener a'I 50 Dkt)-Insp Rept/Notice of Violation

< Response NOTES: App licatior: f or permit r en'eeal f i led. 0<00040 REC IP Ic:-Iwy CQP IES REC IP IENT COPIES ID CODE/NAME LTTR ENCI,. ID CODE/NAME LTTR ENCL Pi> P-1 PD BUCKLEY> B 2 2

. r.'TEP.NAL AEOD DEDRO 1 Nf<R MQR I~'BEAU D NRR/DLPG/PEB 1 1 NRR/Dl PQ, c~AB NRR/DOEA DIR 1 NP. R /DR:-;4." ='P 9 NRR/DREP/RPI3 NRR/DR I 8 D I R NRR/Pl'lAS/ILRB 1 QE LI EBERMA OCC/HDSi 1 1 RES/DRPS DIR 1 1 f<QN2 F I '.E 01 EXTERN'.'AL: LP DR NRC PDR NS:C, TOTAL NUMBER OF COPIES REGUJRED: LTTR 22 ENCL 22

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Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. O. Box 165 New Hill, North Carolina 27562 FF.B 12 1988 File Number'SHF/10-13510E Letter Number: HO-880026 (0)

Document Control Desk NRC-604 United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

In 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 "A" 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, g~~~

R. A. Watson Vice President Harris Nuclear Project MGW: ddj Attachment cc: Messrs. B. C. Buckley (NRR)

G. Maxwell (NRC-SHNPP)

Dr. J. Nelson Grace (NRC-RII) 88021 60256 880212 PDR ADOCK 05000400 6 PDR MEM/HO-8800260/1/OS1

Attachment to CP&L Letter of Response to NRC I.E. Report RII:

50-400/87-38 Violation "A" Re orted Violation:

A. 10CFR50, 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 Po~er 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 consistent 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).

MEM/HO-8800260/1/OS1

Denial or Admission and Reason for the Violation.'he violation is acknowledged in part as specifically discussed below.

1. The intent of ANSI N45.2.11-1974 Section 3.1 is met in appropriate procedures because SHNPP relies on Design Basis Documents (DBD's) to assure that applicable design inputs are identified, documented, and their selection approved. The DBDs are in place at the Harris Plant and the DBDs were developed for this reason. They document applicable drawings, specifications, and calculations, as well as regulatory documents and applicable technical references for safety-related systems. In this respect, the Design Basis Documents are the source for design modifications and the modification process requires that the DBDs be reviewed for adequacy or impact for each and every modification.

The modification developed via PCR-2292 is not considered a problem of design inputs. This modification involved circuit boards 0834, 0843, and 0841 which were each shown on a schematic diagram in two locations. The second location was inadvertently overlooked, as each loop was developed, which led to the use of unavailable contacts in the design.

PCR-1286 added 6 check valves into the AFM system. The PCR and subsequent field revisions correctly gave design inputs as follows:

Valve Added Line Number Line Desi n Pressure PCR-1286 3AF-V221SA-1 3AF4-1SA-1 1700 psig PCR-1286 3AF-V223SA-1 3AF4"6SA-1 1700 psig FR-6 3AF-V222SA-1 3AF4-4SA-1 1700 psig FR-9 3AF-V225SB-1 3AF4-11SB-1 1600 psig FR-9 3AF-V224SB"1 3AF4-9SB-1 1600 psig FR-9 3AF-V226SB-1 3AF4-10SB-1 1600 psig The PCR and Field Revisions correctly identify these design pressures. However, the hydrotest developed for the PCR did not initially contain the correct pressures.

Prior to performing the hydrostatic test for the valves added to lines 3AF4-11SB-1, 3AF4-9SB-1, and 3AF4-10SB-1, it was noted that the incorrect design pressures and hydrotest pressures were denoted on the test report (OgA-304 Enclosure 1). This discrepancy was corrected prior to performing the test, and was due to a personnel error in recording the pressures onto the test report. The tests were performed at the correct pressures in accordance with the ASME Code.

2. The response to item 2 discusses two examples. The violation is denied with respect to the PCR-1391 example and admitted with respect to the PCR-2292 example.

These are addressed separately below.

MEM/HO-8800260/2/Osl

PCR-1391 The purpose of PCR-1391 was to remove certain snubbers. Modifications to other struts was not required. PCR-1391 produced revised tolerances for the remaining struts, therefore, the strut angles were checked as part of the PCR field verification. Setting the struts was not a requirement of the installation work package as implied by the wording of the violation.

Furthermore, the method of verifying quality attributes',

location, dimensions, geometry, etc., is not a part of the design or installation instructions.

The strut angles in question were verified using a straight edge and graduated scale after the proper offset from the perpendicular was calculated for the specified angle. See Figure A for allowable angle. See Figure B for measurement technique. If design tolerances are so tight as to be impractical or unattainable, it becomes a constructibility problem and the design engineer would be notified.

Inspection procedures with specific details on field verification methods are not required. Engineers currently performing field verifications are certified as qualified based on education, experience, demonstrated expertise, and possibly additional training. Detailed procedures are therefore not provided. In the example given, where different angles could possibly be measured from opposite sides of the strut, results obtained still be satisfactory. by a qualified engineer would In PCR 1391, the verifications involved measuring the deviation from the perpendicular of the strut. It is generally measured by placing a straight edge (usually a small framing square) against the face of the lug, which should be parallel with the strut (see Figure B). In

,welding, apparently these lugs are sometimes deflected outward slightly so that the sides are not absolutely parallels This would mean that if the strut were checked by placing a straight edge against each side of the lug, different results could be obtained because the sides of the lug themselves might deviate from the perpendicular slightly. This would provide more conservative results and is therefore not a concern.

The reason the angle of movement is verified, is that the strut's movement to either side is restricted by the sides of the lug. Less freedom of movement, as indicated by the angle tolerance being violated, 'could damage the strut, as the pipe moves. The tolerance is given as (+) or (-), meaning ) or < 90', when measured from one side. If measured from both sides, only the

(-) or < 90'olerance need be considered. Since slight deflection outward of the sides of the lug would allow even greater freedom of movement of the strut, when the tolerance is considered, the as-built condition becomes even more conservative.

MEM/HO-8800260/3/OS1

PCR-2292 The purpose of PCR-2292 was to install a modification to Process Instrument Control (PIC) Cabinet 4. During the installation of PCR-2292, in mode 4 with the reactor trip breakers closed the power to the cabinet 'card frame 8 was intentionally interrupted. This resulted in the generation of a reactor trip due to the fail safe operation of a 1/2 permissive logic. The reactor trip was not expected to occur on the power interruption.

Details on the reactor trip are included in LER-87-056 dated October 26, 1987. The root cause, as specified in the LER, was inadequate installation instructions.

Corrective Ste s Taken and Results Achieved After completion of the installation of PCR 2292, the PIC cabinet was restored to normal operating status. Because the reactor was already shutdown, the only effect of the trip was the insertion of control rods from 6 steps withdrawn.

Corrective Ste s Taken to Avoid Further Noncom liance'.

The MOD-204 procedure has been revised to state, in part, that special installation instructions shall be specified in a modification package. Additionally, a guideline for providing Plant Change Requests (PCRs) with special installation instructions, is presently being developed. This guideline will establish requirements and provide direction for developing special installation instructions and clearance requirements important to the installer implementing modifications. The guideline will assist the engineer/designer with the "thought process" required to develop such instructions.

Date When Full Com liance Will Be Achieved:

It is estimated that the above described guideline will be completed and issued by March 31, 1988.

MEM/HO-8800260/4/OS1

Attachment to CP&L Letter of Response to NRC I.E. Report RII:

5O-4OO/87-38 Violation "A" 0

l2.

- CONE OF LOADING ALLOWED TO PREVENT BINDING OF STRUT IN END ATTACH~T.

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g= TAIJ I.'5 (4) g=, lO I I C CO MS R IN THE SKETCH ABOVE IF THE PIPE HAS MOVEMENT CREATING A 4.5'NGLE AND THE CRAFT USES THEIR i3'ROCEDURAL TOLERANCE WE COULD END UP WITH A TOTAL ANGLE OF 7.5 > 6'REATING A BOUND SITUATION LIMITING THE INSTALLATION TOLERANCE TO 1.5'LUS 4.5'CREATED BY MOVEMENT) EQUALS 6 = 6'LLOWABLE. NO BINDING CREATED.

F'I6.

ME."i/HO-8800260/5/OSl