ML18005A320
| ML18005A320 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/29/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-607 HO-880067-(O), NUDOCS 8803040261 | |
| Download: ML18005A320 (9) | |
Text
,'"t'C CELERATED DISTISBUTION DEMONSTRAON SYSTEM 1
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:8803040261 DOC.DATE: 88/02/29 NOTARIZED: NO ACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION WATSON,R.A.
'arolina Power
& Light Co.
RECIP.NAME RECXPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds'o NRC 880204 ltr re violations noted in Insp Rept 50-400/88-01.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response DOCKET 05000400 NOTES:Application for permit renewal filed.
05000400 D
RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEBllB NRR/DOEA DIR11E NRR/DREP/RPB10A NRR/PMAS/ILRB12 OGC 15-B-18 RES/DRPS DIR eRNAL:
LPDR NSIC COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 RECIPXENT ID CODE/NAME BUCKLEY,B AEOD NRR MORISSEAU,D NRR/DLPQ/QAB10A NRR/DREP/EPB10D NRR/DRIS DXR9A2 OE L N,J REG-F L GN2 FILE 01 NRC PDR COPIES LTTR ENCL 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 A
A D
TOTAL NUMBER OF COPIES REQUXRED:
LTTR 24 ENCL 24
C~L Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0. Box 165 New Hill, North Carolina 27562 FEB 2 9 1988 File Number'SHF/10-13510E Letter Number.'HO-880067 (0)
NRC"607 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50"400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen.'n reference to your letter of February 4, 1988, referring to I.E.
Report RII:
50-400/88-01, the attached is Carolina Power
& Light Company's reply to violations 'A'nd 'B'dentified in Enclosure 1.
It is considered that the corrective actions taken are satisfactory for resolution of the items.
Thank you for your consideration in this matter."
R. A. Watson Vice President Harris Nuclear Project MGW:msb Attachment cc'Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 8803040261 880229 PDR ADOCK 05000400 O
DCD MEM/HO-8800670/Page 1/OS1 P(p
Attachment to CP6L Letter of Response to NRC I.E. Report RII:
50-400/88-01 Violation
'A'e orted Violation.'icensing Condition 2.F requires Carolina Power and Light Company to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the Facility as amended and as approved in the Safety Evaluation Report dated November 12,
- 1983, and the Safety Evaluation Report dated January 12, 1987.
Contrary to the
- above, the requirements of FSAR Section 9.5.1, "limiting conditions for operation, action statements, and surveillance requirements for the fire protection program will be established,"
has not been fully implemented in that the action statements in Procedure FPP-013 for inoperable fire suppression systems do not adequately define the corrective action required.
Section 8.2 of Procedure FPP"013 requires a continuous fire watch to be posted in areas containing redundant systems or components and an hourly fire watch for all other areas when the fire suppression system protecting the area is inoperable.
Procedure FPP-013 does not include any information as to which areas protected by fire suppression systems do or do not contain redundant systems or components.
This is a Severity Level V violation (Supplement I).
Denial or Admission and Reason for The Violation'.
The violation is correct as stated.
Procedure FPP-013 was developed by re-stating the approved technical specifications for the Harris Nuclear Plant.
It was not recognized by the procedure preparer that more guidance was needed in the procedure.
It was anticipated that the Safe Shutdown Analysis Report would be utilized to determine the mitigating actions for inoperable suppression systems.
- However, the final revision is not onsite at the present time.
Corrective Ste s Taken and Results Achieved:
Procedure FPP-013, Section 8.2, was revised (Rev.
- 3) to require that a continuous fire watch be established when a preaction and multicycle sprinkler system is inoperable.
The procedure change will allow the Operations Support Supervisor or his designee to change the fire watch to an hourly if he can determine that no redundant systems or components could be damaged in that area.
MEM/H0-8800670/Page 2/OS1
Corrective Ste s Taken to Avoid Further Noncom liancce'.
It is considered that the revision to FPP-013 as stated above is sufficient to avoid further noncompliance.
Date When Full Com liance Was Achieved:
Full compliance was achieved on February 9, 1988, with approval of FPP-013 Rev. 3.
MEM/HO-8800670/Page 3/OSl
Attachment to CPKL Letter of Response to NRC I.E. Report RII:
50-400/88-01 Violation
'B'e orted Violation.'icensing Condition 2.F requires Carolina Power and Light Company to implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility as amended and as approved in the Safety Evaluation Report dated November 1982 and the Safety Evaluation Report dated January 12, 1987.
Procedure FPT-3302 which is part of the approved fire protection program requires a quarterly Main Drain Test on suppression system in the Reactor Auxiliary Building.
Contrary to the
- above, review of records showed the following discrepancies.'uppression systems 1A-1-190 and lA-2-190 on the 190 elevation, were tested January 17 and August 28, 1987; suppression systems lA-1-286 and lA-2-286 on the 286 elevation, were tested February 4
and August 28, 1987; and suppression systems 1A-1-305 and 1A-2-305 on elevation
- 305, were tested February 4 and July 7,
- 1987, and again on August 28, 1987.
These tests did not meet the quarterly requirements specified by procedure FPT-3302.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for The Violation:
The violation is correct as stated.
Procedure FPT"3302 was not performed on a quarterly basis for suppression systems as noted above..
The subject tests were delayed due to problems encountered in the disposal of water from the drains.
Personnel responsible for initiating mitigating actions failed to recognize that FPT-3302 was not performed within the allowable time period and that compensatory action was required.
Corrective Ste s Taken and Results Achieved:
Although the subject systems were technically inoperable due to the missed periodic test, they would have performed their function based on the successful tests performed before and after the missed test.
MEM/H0-8800670/Page 4/OSl
Corrective Ste s Taken to Avoid Further Noncom liance:
Periodic tests of fire protection features which are not completed by the scheduled due date are now placed on a status board in the Fire Protection office.
In addition, the test task sheet is marked to indicate the Equipment Inoperable Report (EIR) number and Work Request and Authorization (WRSA) number.
The periodic test is then placed on the "Tests With Exceptions" listing of the Daily Batch Report.
Prior to cancelling an EIR, the Daily Batch Report will be checked to determine whether there are other surveillances past due.
Date When Full Com liance Was Achieved:
Full compliance was achieved on January 18, 1988.
MEM/H0-8800670/Page 5/OS1