ML18009A918
| ML18009A918 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/01/1991 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-755 HO-910068-(O), NUDOCS 9106070217 | |
| Download: ML18009A918 (6) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SSION NBR:9106070217 DOC.DATE: 91/06/01 NOTARIZED: NO IL: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 910502 ltr re violations noted in insp rept 50-400/91-06.Corrective actions:LLRT's stopped
& corrective actions taken to avoid further noncompliance
& no further testing until LLRT procedures were revised.
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
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1 RECIPIENT ID CODE/NAME MOZAFARI,B.
AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
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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!
AL NUMBER OF COPIES REQUIRED:
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Carolina Power 8 Light Company P. O. Box 165 ~ New Hill~ N. C. 27562 R. B. RICHEY Vice President Harris Nuciear Project HARRIS NUCLEAR PROJECT P.O.
Box 165 New Hill, North Carolina 27562 JUN 1
f99)
Letter Number.'H0-910068 (0)
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-755 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO ~ 50-400 LICENSE NO. NPF"63 REPLY TO A NOTICE OP VIOLATION Gentlemen:
In reference to your letter of May 2, 1991, referring to I. E. Report RII:
50-400/91-06, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure l.
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, R. B. Richey, Vice President Harris Nuclear Project MGW:kjc Attachment cc.'Ms. B. L. Mozafari (NRC)
Mr. S.
D. Ebneter (NRC RII)
Mr. J.
E. Tedrow (NRC SHNPP)
P106070>f7 910601 pDOClr P5000400 Q
Poi't MEM/HO-9100680/1/Osl r
'n~~i..
t.r t.r V~'(g0
Attachment to CP&L Letter of Res onse to NRC I. E.
Re ort RII:
50-400 91-06 Violation Re orted Violation:
Technical Specification 6.8.1.a requires that written procedures be established
'and implemented covering procedures outlined in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Paragraphs 1.d/e requires administrative procedures for procedure adherence/procedure review and approval.
Administrative Procedure AP-005, Procedure Format and Preparation, Step 5.6.1.15, requires that procedures be written such that a
backflow preventer (check valve) be installed when temporarily connecting a
radioactive system to the instrument air system.
This procedure further specifies that this requirement be incorporated into applicable plant procedures prior to their next use.
Contrary to the above, on April 16, 1991, procedure AP-005 was not properly implemented in that a
backflow preventer was not installed between the radioactive pressurizer sample system and the instrument air system during the performance of local leak rate testing and the test procedure did not incorporate the requirement to install' back flow preventer.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
On April 16,
- 1991, a local leak rate test (LLRT) was performed without a
backflow preventer being installed on the test equipment.
. The violation occurred because ISI personnel were not aware of the requirement to use backflow preventers.
The requirement was added to AP-005 in February,
- 1990, as a corrective action to a
1989 event which resulted in the contamination of the
~
Instrument Air System.
The requirement was not realized by ISI personnel until the NRC resident inspector questioned ISI supervision concerning the test method on April 16, 1991.
- Upon, recognition of the requirement, LLRTs were stopped and procedure ISI-114, General Use of Local Leak Rate Testing Equipment, was revised adding the requirement to use backflow preventers on all test rigs to prevent any potentially contaminated fluids inside the test boundary from entering the instrument or service air systems.
Individual LLRT procedures were not revised at this time due to the frequency of LLRTs being required during the outage.
- However, ISI personnel were instructed to perform a signoff and verification of backflow preventer installation in the comments section of any future tests performed.
MEM/HO-9100680/2/Osl
Denial, or Admission and Reason for the Violation (continued):
On April 22,
- 1991, an LLRT was partially performed without a
backflow preventer installed.
This incident was also observed and brought to ISI personnels attention by the NRC resident inspector.
The test was stopped and a
backflow preventer was installed.
Following completion of this test, all LLRTs were stopped to ensure this matter was adequately resolved.
The cause of the April 22, 1991, incident was due to ISI personnel error.
Although test personnel had been made aware of the requirement of ISI-114 to u'se and verify backflow preventers, the technicians failed to comply with the newly incorporated change.
No contamination event occurred as a
result of these two instances.
Based on subsequent discussions with the manufacturer of the leak rate monitoring equipment, backflows 'to the pressure source would be unlikely even without a backflow preventer due to the monitor design which employs an 'adjustable regulator that allows flow in only one direction.
Corrective Ste s Taken and Results Achieved:
Upon identification of both instances of noncompliance, LLRTs were stopped and corrective measures were taken to avoid further noncompliance.
After the April 22,
- 1991, incident, no further testing was performed until the individual LLRT procedures were revised and applicable ISI personnel were formally instructed on the use of backflow preventers.
Corrective Ste s Taken to Avoid Further Violations.'ncorporation of the requirement for backflow preventers into procedure ISI-.114 which covers the general use of LLRT equipment and revision to the individual LLRT procedures and subsequent training as mentioned above should avoid any further violations of this type.
Date When Full Com liance Will Be Achieved:
Full compliance was achieved on April 23, 1991, with completion of training of appropriate ISI personnel.
MEM/HO-9100680/3/OS1