ML18009A879
| ML18009A879 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/26/1991 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-752 HO-910045-(O), NUDOCS 9104300232 | |
| Download: ML18009A879 (8) | |
Text
ACCELERATED DISTMBUTlON DEMONSTfWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9104300232 DOC.DATE: 91/04/26 NOTARIZED: NO CIL: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 05000400
SUBJECT:
Responds to NRC 910327 ltr re violation
& deviation insp rept 50-400/91-03.Corrective actions:PASS semi-annual training recpxirements clarified
& inc into plant procedures
& will participate in semi-annual hands-on PASS training.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL 2'IZE-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/DOEA/OEAB NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR RE +
EXTERNAL EG&G/BRYCEIJ
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NSIC COPIES LTTR ENCL 1
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RECIPIENT ID CODE/NAME BECKER,D AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS 1 RGN2 FILE 01 NRC.PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELliVllNATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24 D
D
0 0
CMk Carolina Power 8 Light Company P.O. Box 165 ~ New Hill,N. C. 27562 R. B. RICHEY Vice President Harris Nuclear Project p,pR 2 6
1991 Letter Number.'HO-910045 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-752 I
Gentlemen:
SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION AND DEVIATION In reference to your letter of March 27,
- 1991, referring to I.E. Report RII:
50-400/91-03, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure 1 and the deviation identified in'nclosure 2.
It is considered that the attached response is satisfactory for resolution of the items.
I Thank you for your consideration in this matter.
Very truly yours, R. B. Richey Vice President Harris Nuclear Project MGW:kjc Enclosures
'I cc:
Mr. R. A. Becker (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC SHNPP) 9104-~00232 yg042z F'DR ADOCl2 05000400 2
A PDF" MEM/HO-9100450/1/OS1
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Enclosure 1
to CPhL Letter of Res onse to NRC I.E.
Re ort RII:
50-400 91-03 Re orted Violation.'echnical Specification 6.8.4.e requires that a
post-accident sampling program be implemented to ensure, the capability to obtain and
. analyze reactor
- coolant, plant gaseous effluents, and containment atmosphere samples.
The program shall'nclude procedures for'sampling and analysis.
Regulatory Guide 1.33, Appendix A,
Paragraph 10, requires that chemical and radiochemical control procedures should be written to prescribe the nature and frequency of chemical and radiochemical sampling and analyses.
Contrary to the
- above, on February 28, 1991, it was determined that the licensee did not have a written procedure detailing the necessary steps for the removal of a post-accident, undiluted, reactor coolant sample from the shielded container in which it is
-collected.
This is a Severity Level IV violation (Supplement IV).
Denial or Admission of the Violation.'he violation as stated above is =denied.
It is CPSL's position that a specific procedure for this task was not required for the following reasons:
Plant Procedure CRC-821, "Post-accident RCS/RHR Sampling",
specifies when and how the reactor coolant sample is to be obtained and analyzed.
Plant Procedure CRC-502, "Operation of the Dionex Q.I.C. Ion Chromatograph for Anion Analysis" specifies how to perform chloride analysis on-site.
Per CRC-821, a diluted reactor coolant sample is to be analyzed on-site and an undiluted reactor coolant sample is to be obtained in the portable. shielded container "pig."
The undiluted liquid sample is used to meet the NUREG-0737, II.B.3 requirement for chloride analysis of an undiluted reactor coolant sample within 30 days.
The undiluted sample can be analyzed on-site. or sent. off.-sj,te.for analysis.
The off-site analysis option can be exercised by the Radiological Control Director and the Chemistry Coordinator for any
- reason, e.g.,
'high dose rates from the undiluted sample.
Recognizing the need for this option, CPhL maintains a contract with a vendor to perform analysis of highly radioactive samples off-site.
MEM/HO-9100450/2/Osl,
Denial or Admission of the Violation: (continued)
The "mechanics" of removing the sample from the "pig" is simplistic and straight forward.
Depending on the dose rates which can be determined from the diluted sample and portable survey instruments, effective radiation protection precautions would be prescribed.
This is consistent with many plant activities involving potential highly radioactive materials.
CRC"821 states in several sections the need for using ALARA principles, Radiation Work Permits, and Radiation Control (RC) technician coverage during PASS
- sampling, sample transport and analysis.
Many other plant procedures, both normal operation procedures and emergency procedures, address handling and storing radioactive materials including samples.
Because of these procedures and the RC related wording in PASS procedures, no specific written procedure was written for this task.
It is CPSL's position that a specific procedure was not needed.
- However, as stated in the Exit Interview for this inspection, CP&L agreed to prepare specific written. instructions to enhance our program.
We also stated at the Exit Interview that we considered this a program enhancement and not,a requirement.
A revision to CRC-821 will provide instructions for retrieval of the undiluted liquid sample from the shielded container.
This revision will address the need for evaluating the radiological hazards and the identification of protective measures.
The specific requirements will depend on the activity level of the sample in question which can be estimated from the analysis of the diluted sample.
This revision wi'll be completed by June 15, 1991.
MEM/HO-9100450/3/OS1
Enclosure 2 to CP&L Letter for Res onse to NRC I.E.
Re ort RII:
50-400 91-03 Re orted Deviation.'he licensee committed, in correspondence to the Office of Nuclear; Reactor Regulation, dated May 19,
- 1988, to semiannual retraining of the chemistry technicians qualified to operate the Post Accident Sampling System.
Contrary to the above, it was determined on February 28,
- 1991, that chemistry technicians qualified to operate the, Post Accident Sampling System were not be'ing retrained semiannually.
Reason for the Deviation Participation by chemistry technicians in the quarterly Post Accident Sampling System (PASS) operability testing was intended to be used to meet the semi-annual retraining commitment.
Credit for training was given for either PASS Sampling
,or Laboratory Analysis of PASS Samples.
The expectation was that with normal
- rotation, a sufficient number of technicians would have completed hands-on training at least twice a year.
Some technicians did complete the twice a
year training commitment.
- However, more attention was placed on the'cheduling and completion of the quarterly operability test than on which technicians were conducting the tests, resulting in fewer than expected technicians receiving the semi-annual retraining.
Corrective Ste s Planned to Prevent Further Deviations:
The PASS semi-annual training requirements and the documentation of training completion will be clarified and incorporated into plant procedure, CRC-830, "Periodic Maintenance and Operability Verification of the PASS."
A group of approximately ten chemistry technicians will be designated as.
"PASS operators" and will participate in the semi-annual hands-on PASS training.
Date When Corrective Actions will be Com leted:
The revision to CRC-830 will be completed by June 30, 1991, with implementation of the revised training program beginning by July 1, 1991
'EM/HO-9100450/4/OS1
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