Responds to NRC Re Violations Noted in Insp Rept 50-400/90-06.Corrective Actions:Procedures OST-1008 & OST-1108 Revised to Delete Stroke Testing of Valve 1ST-359 on Quarterly Basis
HNP-99-091, Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs
ML18016A974
ML20212H752
HNP-99-103, Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated
HNP-99-094, Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service, .Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration
ML18016A996
ML18016A988
ML18016A992
ML20212H774
ML18016A998
ML18016B002
ML18016A997
HNP-99-104, Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl
HNP-99-114, Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP
HNP-99-113, Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930
HNP-99-119, Informs That in Ltr CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998
HNP-99-116, Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed
05000400/LER-1999-006-01, Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS
ML18016B055
ML18016B054
HNP-99-163, Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl
HNP-99-128, Corrects Statement Made in ,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment
ML18017A844
HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21
ML18017A848
HNP-99-130, Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided
ML14314A777
HNP-99-136, Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS
HNP-99-129, Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity
HNP-99-127, Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety
HNP-99-140, Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6)
ML18017A884
ML18017A907
HNP-99-143, Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations
ML18017A885
ML18017A902
ML18017A903
HNP-99-145, Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii)
ML20212J074
ML20216G350
HNP-99-142, Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves
ML20212M108
ML18017A891
ML18017A899
ML14181A464
ML18017A895
HNP-99-148, Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld
IR 05000400/1999007
HNP-99-153, Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon
HNP-99-156, Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools C & D in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration
HNP-99-017, Informs NRC of Mod to Commitment for Hnp,Re Comprehensive Review of Implementation of TS Sr.Upon Completion of Listed Reviews,Surveillance Procedure Review Project Will Be Considered Complete
HNP-99-032, Forwards Proprietary & non-proprietary Version of Rev 3 to HI-971760, Licensing Rept for Expanding Storage Capacity in Harris SFPs C & D. Repts Are Reissued to Reflect Reduction in Proprietary Info.Proprietary Info Withheld
ML18016A869
HNP-99-053, Submits Response to RAI Re Spent Fuel Pool Water Level & Revised Fuel Handling Accident Analyses,Per 990317 Telcon with NRC
HNP-99-034, Forwards Shnpp Operator Training Simulator,Simulator Certification Quadrennial Rept, IAW 10CFR55.45(b)(5)(ii). NRC Form 474 & Required Info Re Simulator Performance Test Results & Schedules Also Encl
HNP-99-051, Responds to NRC Re Violations Noted in Insp Rept 50-400/98-11.Corrective Actions:Post Trip/Safeguards Actuation Rept for 981023,RT Was Corrected,Required Reviews Completed & Approval Obtained on 990219
HNP-99-024, Forwards Rev 99-1 to Plant EALs for NRC Review & Approval, Per 10CFR50,App E.Encl Provides Comparison of Currently Approved EALs & Proposed Rev 99-01.Approval of EALs Prior to June 1999,requested.With Four Oversize Drawings
HNP-99-059, Forwards non-proprietary App 4A,pages 20-25 & Proprietary Page 4-6 to re-issued Rev 3 of Holtec International Licensing Rept HI-971760.Pages Were Inadvertently Omitted from Reissued Rept.Proprietary Page 4-6 Withheld
HNP-99-058, Forwards Diskette Containing Data Re Annual Exposure Rept for Individual Monitoring for Personnel Shnpp,Per 10CFR20.2206(b).Without Encl
HNP-99-065, Forwards Rev 34 to PLP-201, Shearon Harris NPP Emergency Plan, Replacing All Pages of Previous Rev with Exception of EAL Flow Path,Side 1 & 2 & Annex H Operations Map & Aperture Card.Changes,Listed.Rev Summary,Encl
HNP-99-067, Informs of HNP Personnel Changes to Facilitate Proper Distribution of Correspondence.Records Should Be Updated to Reflect Noted Change
HNP-99-072, Forwards Proprietary NRC Form 396, Certification of Medical Exam by Facility Licensee, for SRO Licensed to Operate Hnp. License for Individual Should Be Amended IAW Change Noted on Form.Proprietary Encl Withheld,Per 10CFR2.790(a)(6)
HNP-99-070, Provides Rev 2 to ISI Relief Request 2RG-008, ISI of Class 1,2 & 3 Snubbers (Code Category F-A) Per Plant TS in Lieu of ASME Code Section XI, in Response to 990408 Telcon with NRC
HNP-99-076, Forwards Proprietary Notification That SRO Licensed on Shnpp Has Terminated Employment with Cp&L,Per 10CFR50.74(b). Proprietary Info Withheld,Per 10CFR2.790(a)(6)
HNP-99-068, Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld
HNP-99-074, Forwards Annual Radioactive Effluent Release Rept for Jan- Dec 1998 & Rev 11 to ODCM for Shnpp
HNP-99-069, Forwards Info Requested in 990324 RAI as Suppl to 981223 Application for Amend to License NPF-63 for Alternative Plan for Spent Fuel Pool Cooling & Cleanup Sys Piping
HNP-99-060, Notifies NRC of Util Completion of Actions Re GL 96-01, Testing of Safety-Related Logic Circuits at Plant
HNP-99-084, Provides Proprietary Notification That One SRO Has Been Reassigned from Position for Which Util Certified Need for SRO License & Another SRO Has Terminated Employment with Util.Proprietary Info Withheld,Per 10CFR2.790(a)(6)
ML20206R261
HNP-99-085, Forwards NRC Form 396, Certification of Medical Examination by Facility Licensee, for Senior Reactor Operator Licensed to Operate Hnp.Individuals Info Is Proprietary & Is Being Withheld from Public Disclosure,Per 10CFR2.790(a)(6)
HNP-99-088, Submits Info Re Estimated Effect of Change to ECCS Evaluation Model,As Required by 10CFR50.46
HNP-99-087, Forwards Periodic Update to FSAR for Hnp.Amend 49 Is Current Through 981128 (End of RFO 8).Some Changes & Analysis Completed After 981128 Have Also Been Included in Amend
ML18016B001
HNP-99-091, Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs
ML20212H752
HNP-99-103, Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated
HNP-99-094, Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service, .Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration
HNP-99-104, Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl
HNP-99-114, Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP
HNP-99-113, Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930
HNP-99-116, Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed
HNP-99-119, Informs That in Ltr CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998
05000400/LER-1999-006-01, Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS
HNP-99-163, Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl
HNP-99-128, Corrects Statement Made in ,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment
HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21
HNP-99-130, Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided
HNP-99-136, Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS
HNP-99-129, Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity
HNP-99-127, Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety
HNP-99-140, Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6)
HNP-99-143, Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations
HNP-99-145, Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii)
ML20212J074
HNP-99-142, Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves
ML18017A891
HNP-99-148, Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld
HNP-99-153, Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon
HNP-99-156, Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools C & D in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
Carolina Power 8 Ught Coinpany P. O. Box 165 ~ New Hill~ N. C. 27562 R. B. RICHEY Manager Harrla Nuclear Prelect MAY B 0 1990 Letter Number:
HO-900095 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-714 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 May 4,
1990, referring to I.E.
Report RII:
50-400/90-06, the attached is Carolina Power and Light Company's reply to violation "A" 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, R. B. Richey, Manag r Harris Nuclear Proj ct MGW:msb Enclosure cc'.
Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC SHNPP) 0 00qe 900 5'00' ~I OC'i 0 i0r>0gi< g PDC 4lEM H0-9000950/1/OS1
Technical Specification 4.4.6.2.2.d requires that with the plant operating at po~er, leakage by a reactor coolant system pressure isolation valve shall be verified to be within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation.
Contrary to the
above, during power operation from March 1987 through February 13,
1990, reactor coolant system pressure isolation valve 1SI-359 has been manually actuated on approximately 13 different occasions without the subsequent performance of leakage verificat'ions.
Denial or Admission and Reason for the Violation.'he violation is correct as stated.
Technical Specification (TS) 4.4.6.2.2.d requires that Reactor Coolant System Pressure Isolation Valves specified in Table 3.4-1 shall be demonstrated operable by verifying leakage to be within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valves.
Safety Injection Valve 1SI-359, Hot Leg Recirculation Valve, is included in this table.
This test stroked valve 1SI-359 along with several other valves.
The valve cycling in OST-1008 is required by the Inservice Inspection Program (ISI)-203, ASME Section XI 'Pump and Valve Program Plan.
On April 5, 1990, during an Inservice Inspection revie~ of the stroke times for the RHR valves, it was discovered that valve 1SI-359 was required to be leak tested following the stroke time testing.
However, OST-1008 did not identify the requirement for leak testing.
A review of previously performed OSTs has been completed and revealed that valve 1SI-359 has never been leak tested following the performance of OST-1008, or OST-1108, RHR Pump Operability
'uarterly
Interval, as required by TSs.
However, the valve has been successfully leak tested previously on December 16,
1989, and October 10,
1988, to satisfy the requirements of Surveillance 4.4.6.2.2.b.
MEM/HO-9000950/2/OS1
Denial or Admission and Reason for the Violation.'(contiaued)
The cause of the event is inadequate procedural controls for identifying when the particular surveillance was required.
When the initial Inservice Testing Program for Pumps and Valves was developed, the procedure (ISI-203) did not require the cycling of this valve during routine plant operations.
An ASME Section XICold Shutdown justification was used to require valve cycling only when the plant was in Cold Shutdown if the test had not been completed in the previous quarter.
This approach was approved by the NRC in the acceptance of the original version of the Inservice Valve Testing program.
Notwithstanding
this, OST-1008 and OST-1108 included the steps for cycling 1SI-359.
Subsequently, in March 1989, 1SI-203 was revised to require quarterly testing.
In the development of. the specific OSTs, it was not recognized that the cycling of 1SI-359 would lead to the requirement for a specific leak test.
The need for the leak test was also part of a separate plant matrix covering "event related" surveillances.
This matrix listed "event related" surveillances, the procedures which would identify and trigger the performance of the surveillance and the procedure implementing the surveillance.
This matrix shows that the need for the leak test surveillance would be initiated only by actuation of the Safety Injection System.
The matrix did not recognize that cycling of valve 1SI-359 would occur on a routine basis.
Corrective Ste s Taken and Results Achieved:
On April 5,
1990, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> valve 1SI-359 was declared inoperable, and the plant entered Limiting Condition of Operation (LCO) action 3.4.6.2.c.
The valve was then leak tested utilizing OST-1506, Reactor Coolant System Isolation Valve Leak Test.
OST-1506 was completed satisfactorily and the valve was declared operable at 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />.
Corrective Ste s Taken to Prevent Further Violations:
The following corrective actions will be implemented to prevent further violations.
1.
OST-1008 and OST-1108 will be revised to delete the stroke testing of valve 1SI-359 on a quarterly basis.
2.
The stroke testing of valve 1SI-359 will be included in OST-1088, Low Head SICheck ValvesISI TEST Quarterly Interval Mode 5.
Leak testing will be done prior to entry into Mode 2.
3.
Appropriate personnel will be trained on this event.
MEM/HO-9000950/3/OSl
l) 0
Corrective Ste s Taken to Prevent Further Violations (continued) 4.
ISI-203 was revised on April 17,
1990, to change the test frequency of valve 1SI-359 to COLD
SHUTDOWN, quarterly interval, instead of during plant operation.
5.
A change to TS Table 3.4-1 will be submitted to the NRC to change the testing frequency of valve 1SI-359.
6.
The "event'elated" TS surveillance matrix will be reviewed for any similar problems.
Date When Full Com liance Will Be Achieved The corrective actions stated above are expected to be completed by July 13, 1990.