ML18005A313
| ML18005A313 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/26/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| HO-880074-(O), NUDOCS 8803010490 | |
| Download: ML18005A313 (7) | |
Text
REGULA Y INFORMATION DISTRIBUTI YSTEM (RIDS)
ESSION NBR: 8803010490 DOC. DATE: 88/02/26 NOTARIZED:
NO
ACIL: 50-400 SheaY on Harv is Nuclear Poeer Plant>
Unit 1> Carolina AUTH. NAME AUTHOR AFFILIATION WATSON> R. A.
Carolina Poeer h Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 880129 ltr re violation>s noted in Insp Rept 50-400/87-40. Supp 1 cmental resp onse to vio lation 50-400/87-31-02 encl. Corrective actions: Procedure AP-615>
used to evaluate events for reporting to NRC mill revised.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR I
ENCL j SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Application for permit reneujal filed.
DOCKET 0 05000400 05000400 REC IP IENT ID CODE/NAME PD2-1 PD INTERNAL:
ACRS DEDRO NRR/DLPG/PEB11B NRR/DOE* DIR11E NRR/DREP/RPB10A NRR/PMAS/ ILRB12 OGC 1 5-9-18 RES/DRPS DIR COPIES LTTR ENCL 1
1 1
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REC IP IENT ID CODE/NAME BUCKLEY> B
- EOD NRR MORISSEAU> D NRR/DLPQ/G*B10A NRR/DREP/EPB10D NRR/DRIS DIRVA2 O~E.L.I,EBERMAN> J
@GREC F ILQ RGN2 FILE 01 COPIES LTTR ENCL 2
2 1
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1 EXTERNAL: LPDR NSIC 1
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1 NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
S
~L Carolina Power & Ltght Company HARRIS NUCLEAR PROJECT P. 0. Box 165 New Hill, NC 27562 FEB 26 1988 File Number'SHF/10-13510E Letter Number'.
HO-880074 (0)
NRC-612 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen.'s requested by your letter dated January 29,
- 1988, (IE Report 50-400/87-40),
attached is Carolina Power and Light Company's supplemental response to violation 50-400/87-31-02.
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, AD R. A. Watson Vice President Harris Nuclear Project MGW:ddl Attachment cc'.
Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 88030i0490 880226 PDR ADOCK 05000400 Q
PDR P~g,n MEM/HO-8800740/1/OS1
Supplemental
Response
to NRC Violation 50-400/87-31-02 The Ori inal Re orted Violation is as stated below'.
10CFR50.72 requires that the licensee notify Center via the Emergency Notification System condition results in manual or automatic engineered safety feature (ESF).
The event reported within four hours of its occurrence.
the NRC Operations when any event or actuation of any is required to be Contrary to the above, on August 5,
- 1987, the licensee failed to report an automatic actuation of the auxiliary feedwater system within the required four-hour time period.
The actuation of this ESF system occurred at 2:01 a.m.
and was not reported to the NRC Operations Center until 9:44 a.m.
This is a Severity Level V violation (Supplement 1).
The above violation identified that CPEL had failed to report under 10CFR50.72 that the auxiliary feedwater system sustained an automatic initiation on August 5, 1987.
NRC I.E.
Report 50-400/87-40, dated January 29, 1988, identifies three additional instances where CPSL did not report plant events as required under 10CFR50.72.
These three additional events were due to breach of containment building integrity caused when both the inner and outer personnel air lock doors were open at the same time or one was opened while the other was declared inoperable.
As requested, CP6L provides the following supplemental response to address these additional events.
Denial or Admission and Reason for the Violation.
This response addresses only the additional examples proposed in report 50-400/87-40.
The violation is accepted.
The inspection report states that each of these events should have been reported to the NRC upon initial discovery in accordance with 10 CFR Paragraph 50 ~72.b.(2).(iii).
This paragraph requires reporting of "Any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to'.
(D) Mitigate the consequences of an accident."
The events described in the LER's involve 4
separate episodes where the Technical Specifications LCO and action statements were not satisfied.
In summary, these events consisted of:
1.
On June 11, 1987, both doors failed seal leakage tests.
The requirements of T.S. 3.0.3 were applied and the outer door was successfully tested within two hours of entry into 3.0.3.
Reporting under 50.72(b)(1)(a)(i)(A) would have been made if a plant shutdown had commenced.
MEM/HO-8800740/2/OS1
2.
On June ll, 1987, the outer door seal failed to remain in its track during an opening and resulted in declaration of the inoperability of the door.
The door closed satisfactorily.
However, prior to the door successfully passing a leak rate
- test, the operable door was used for containment access and egress in violation of T.S. 3.6.1.3.
When tested; the door seal leakage was found to be satisfactory.
3.
On August 31, 1987, the outer door seal failed to remain in its track during an opening and resulted in a declaration of inoperability pending a successful test.
The door was closed successfully.
- However, prior to the door successfully passing a leak rate test, the operable door was used for containment egress in violation of T.S. 3.6.1.3.
When
- tested, the door seal leakage was found to be satisfactory.
4.
On September 17,
- 1987, the outer door failed to completely close and latch.
While personnel were working on the
- problem, personnel opened the inner door by bypassing the door interlocks intended to keep the inner door closed while the outer door was not in the fully closed position.
In each of these
- events, the containment integrity, as defined in Technical Specifications, was not maintained.
- However, the fourth event produced the complete loss of the isolation function of the personnel airlock.
The NRC notification was not made in any of these cases because the procedure, which is used to classify events with regard to NRC notification, does not provide specific example of the personnel air lock and because the event produced only a momentary loss of containment integrity.
Corrective Ste s Taken and Results Achieved:
Each of these events was reported to the NRC under the LER reporting system.
The LERs discussed the immediate steps taken to reestablish the integrity of the personnel
- airlock, increase administrative controls over use of the airlock, and investigate actions to further increase the reliability of the airlock.
Corrective Ste s Taken to Avoid Further Noncom liance.
The procedure (AP-615),
used to evaluate events for reporting to the NRC, will be revised to provide improved guidance for events which involve degradation of a safety function and thus require reporting to the NRC under 10CFR50.72.
Date When Full Com liance Will Be Achieved:
Full compliance will be achieved upon revision of procedure AP-615.
It is projected that AP-615 will be revised by April 1, 1988.
MEM/HO-8800740/3/OS1