ML18005B048
| ML18005B048 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/12/1989 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-680 HO-890092-(O), NUDOCS 8909180098 | |
| Download: ML18005B048 (7) | |
Text
ACCK1ZRATZD D181'KBU'HON DEMONSTRA,T10N SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:8909180098 DOC.DATE: 89/09/12 NOTARIZED-NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION RICHEY,R.B.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 4
05000400
SUBJECT:
Responds to NRC 890821 ltr re violations noted in Insp Rept 50-400/89-15.
DISTRIBUTION CODE IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application,for permit renewal filed.
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05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DLPQ/PEB NRR/DREP/EPB 10 NRR/PMAS/ILRB1 2 0
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RECIPIENT ID CODE/NAME BECKER,D AEOD AEOD/TPAD LOIS, ERASMIA NRR/DEST DIR NRR/DOEA DIR 11 NRR/DREP/RPB 10 NUDOCS-ABSTRACT OGC/HDS1 RES MORISSEAU,D NRC PDR COPIES LTTR ENCL 1
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LTTR 26 ENCL --- D S
Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.O.
Box 165 New Hill, North Carolina, 27562 SEP 1 21889 File Number.'HF/10-1351GE
.Letter Number.
H0-890092 (0)
Document Control Desk l.
United States Nuclear Regulatory Commission Washingt'on, DC 20555 NRC-680 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen.
In reference to your letter of August 21, 1989, referring to I.E.
Report RII:
50"400/89-15, the attached is Carolina Power and Light Company's reply to violation "B" identified in Enclosure l.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours, MGW:djs Enclosure R. B. Richey, Ma ger Harris Nuclear Project cc'.
Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. M. C. Shannon (NRC SHNPP) 8909180098 890912 PDR ADOCK 05000400 rq PDI..
MEM/HO-8900920/1/OS1
ATTACHMENT TO CPSL LETTER OF
RESPONSE
TO NRC I'D REPORT RII: '50-400/89-15 VIOLATION "B" Re orted Violation'.
~
10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and
- Drawings, and the Carolina Power and Light Company Corporate Quality Assurance
- Program, Section 6,
requires that activities affecting quality shall be prescribed by documented instructions, procedures, or 'rawings and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to accomplished drawings in flow orifice maintenance verification the
- above, activities affecting quality were not in accordance with instructions, procedures, or that the containment spray system NAOH tank outlet FE
- 7152, was installed backwards while performing Work Request 86-AGQM1, and the QC hold point for of flow direction was initialed as acceptable.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
Both the maintenance installation and the QC inspection are considered to be contributors to the violation.
On May 30,
- 1986, Maintenance reinstalled the Containment Spray System Sodium Hydroxide Tank outlet flow orifice, FE-7152.
Work was controlled under WR6A 86-AGQM1.
A "Start-Up Flanged Connection Form" was used as the process control document, and QC Holdpoints were assigned.
The process control document also referenced applicable information such as line number, drawing
- number, and code class.
The reason for the improper installation of the flow orifice by maintenance personnel cannot be determined.
The personnel involved 'are no longer employed at the Harris Nuclear Project.
The flow orifice handle was clearly marked for installation purposes.
Proper orientation and post installation verification should not have been a problem.
During reinstallation, the "Valve/Speciality Item Flow
- surfaces, gaskets, fasteners, results and other pertinent process control document.
A that holdpoints were initialed QC Inspector was to verify Direction",
as well as mating lubricant and torque.
Inspection information were recorded on the review of this document indicates as acceptable.
MEM/HO-8900920/2/Osl
The flow element was clearly marked to indicate flow direction, and the referenced isometric drawing correctly showed the flow direction.
To the assigned inspector, who was fully qualified and certified, this would have been a routine inspection.
Therefore, it is concluded that error on the part of the QC Inspector is a
contributing cause to the improper installation of the flow element.
Corrective Ste s Taken and Results Achieved:
Maintenance work request 89-ALTG1 was generated to
- remove, inspect, and reinstall the flow element in the proper orientation.
On August 8,
- 1989, the system flow element was
- isolated, the flange disassembled, and the flow element was removed and inspected.
It was found to be installed backwards.
The flow orifice was reinstalled with appropriate QC verifications.
The QC Inspector involved is no longer employed by the Company.
QA/QC is currently identifying other inspections performed by this Inspector for purposes of reinspection.
Reinspection will be performed until a satisfactory confidence level is achieved.
This reinspection effort is currently in progress
- and, to date, no other problems have been identified.
This effort is expected to be completed by January 29, 1990.
Corrective Ste s Taken to Avoid Further Violations.
Maintenance Mechanics are required to attend Continuing Training classes quarterly.
The training is conducted by t:he Harris Training Unit at the Harris Plant.
In the fourth quarter of 1989, this training will include a
session on flow measurement devices.
The training will include discussions on flow element orientation in a flow stream.
This training is expected to be completed by October 31, 1989.
A training class will be held for certified QC Mechanical Inspectors.
This training will cover flow elements, flow paths, and attention to detail when performing inspections.
This training is expected to be completed by October 2, 1989.
Date When Full Com liance Mill be Achieved:
Full compliance is pending the completion of the above mentioned training for both maintenance and QC personnel and the reinspection effort which is expected to be completed by January 29, 1990.
MEM/HO-8900920/3/OS1
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