ML18010A428
| ML18010A428 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/07/1991 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HO-910210-(O), NUDOCS 9111140176 | |
| Download: ML18010A428 (7) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM t
t REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9111140176 DOC.DATE: 91/11/07 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 D
/
05000400 A NOTES:Application for permit renewal filed.
SUBJECT:
Responds to NRC 911009 ltr re violations noted in Insp Rept 50-400/91-21.Corrective actions:procedure guidance developed for corrective maint on Crosby relief valves
& personnel trained re correctly positioning nozzle rings.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE I.R RGF ~2 EXTERNAL: EG &G/BRYCE, J. H.
NSIC COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME MOZAFARI,B.
AEOD AEOD/DSP/TPAB NRR HARBUCK,C.
NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC N2 F
NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24 A
D D
Carolina Power & Light Company P.O. Box 165 ~ New Hill, N.C. 27562 HARRIS NUCLEAR PROJECT R. B. RICHEY Vice President Harrts Nuclear Project NOV
'7 )99]
Letter Number:
HO-910210 (0)
Document Control Desk Un'ed Stat:es Nuclear Regulatory Commission Washington, DC 20555 NRC-767 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 October 9,
1991, referring to I.E.
Report RII:
50-400/91-21, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure 1.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Ve~~
truly yours, R.
B. Richey Vice President Harris Nuclear Project MV:dmw Attachment cc:
Ms. B. L. Mozafari (NRC)
Mr. S.
D. Ebneter (NRC - RII)
Mr. J.
E. Tedrow (NRC -
SHNPP)
MEM/NRC-VIOL/1/OS1 9111140176 911107 PDR ADOCK 05000400 O
Attachment to CP&L tter of Res onse to NRC I.E.
e ort RII: 50-400 91-21 Violation Re orted Violation:
Technical Specification 6.8.l.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, paragraph 9 requires procedures for the conduct of maintenance activities.
Contrary to the above, a procedure for the conduct of maintenance activities to properly set the blowdown rings on Crosby relief valves in a variety of safety-related systems was not properly established.
This subsequently contributed to the loss of component cooling water inventory following a safety valve lift on August 8, 1991.
This is a Severity Level IV violation (Supplement I).
Denial or Admission and Reason for the Violation:
The violation is admitted.
It is acknowledged that a procedure to provide guidance on the proper setting of Crosby relief valve blowdown rings had not been established prior to the August 8,
1991 loss.of Component Cooling Water inventory event.
During the investigation of this event, management discovered that maintenance personnel were not consistently interpreting the data contained in the manufacturer's relief valve test data report.
The specific section that created confusion was the process that determined the blowdown ring "level position".
Instructions on how to determine this "level position" were not clear in the test data report and were not contained in the associated vendor technical manual.
The inability to properly interpret the test data report and determine the "level position" subsequently led to the incorrect setting of blowdown rings and prevented the relief valves from reseating at their required pressures.
Prior to this event, the actual task of setting these blowdown rings was determined to be a relatively uncomplicated task that would be "within the skill of the technician".
Therefore, no step-by-step procedure was determined to be necessary.
Corrective Ste s Taken and Results Achieved:
Upon discovery that this task involved a process that was not clearly delineated in the test data report or the vendor technical manual and was leading to incorrect interpretations by maintenance personnel, efforts began to develop a
procedure with step-by-step guidance.
This procedure (CL-ME0042) was approved on 8/22/91.
Additional procedure guidance was also developed for corrective maintenance on Crosby relief valves.
CM-M0192 (Crosby relief valve disassembly, maintenance and reassembly) was approved on 11/6/91.
Personnel involved in
. investigating and resetting incorrectly positioned nozzle rings have been trained on the proper method.
MEM/NRC-VIOL/3/OS1
Cl'
Corrective Ste s Tak o Prevent Further Violations:
The corrective actions stated above have been completed.
No further action will be required.
Date When Full Com lienee Will Be Achieved:
Procedure CL-ME0042 has been developed and was approved on 8/22/91.
Procedure CM-M0192 has been developed and was approved on ll/6/91.
Training on the proper method for setting blowdown nozzle rings was completed for applicable Maintenance personnel on 10/22/91.
MEM/NRC-VIOL/3/OS1