ML18010A640
| ML18010A640 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/12/1992 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-781 HO-920085, NUDOCS 9205190297 | |
| Download: ML18010A640 (8) | |
Text
ACCELERATED DISTRIBUTION DEMONST TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
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ACCESSION NBR:9205190297 DOC.DATE: 92/05/12 NOTARIZED:
NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina
,AUTH.NAME AUTHOR AFFILIATION VAUGHN,G.E.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Responds to NRC 920413 ltr re violations noted in insp rept 50-500/92-04.Corrective actions:procedures OMM-014
& TMM-100 will be revised by 920630
& 920601,respectively.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of VioTation Response D
NOTES:Application for permit renewal filed.
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A RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 COPIES LTTR ENCL 1
1 2"
2 1
1 1
1 1
1 1
1 1
1 1
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1 RECIPIENT ID CODE/NAME MOZAFARI,B.
AEOD AEOD/DSP/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR PMAS/ILRB12'
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REG FILE 02-COPIES LTTR ENCL 1
1 1
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EXTERNAL: EG&G/BRYCE,J.H.
NSIC 1
1 NRC PDR 1
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iNOTE TO ALL"RIDS" RECIPIENTS:
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PLEASE HELP US TC RLDUCI' ASTE! CONTACT THE DOCUii'IENTCONTROL DESK, ROOivl P 1-37 (EXT. %79) TO L'LIMINATEYOUR NAME FROiiI DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 23 ENCL 23
CHILL Caroiina Power 8 Light Company P.O. Box 165 ~ New Hill, NC 27562 MAY )
P
>992 G. E. VAUGHN Vice President Harris Nuctear Project Letter Number:
HO-920085 Document Control Desk-United States Nuclear Regulatory Commission Washington, DC.
20555 NRC-781" 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 April 13, 1992, referring to NRC Inspection Report RII:
50-400/92-04, the attached is Carolina Power and Light Company's reply to'he violations identified in Enclosure 1.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the violations.
Thank you for your consideration in this matter.
Very truly yours, G.
E. Vaughn Vice President
, Harris Nuclear Project MGW:dmw Attachment cc:
Mr. S.
D. Ebneter (NRC-RII)
Ms.
B. L. Mozafari (NRC)
Mr. J.
E. Tedrow (NRC-SHNPP) y~ii MEM/HO-920085/1/OS1 92051902'P7 920512 PDR ADOCK 05000400 Q
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-04 VIOLATION 400 92-04-01 Re orted Violation:
10 CFR 50, Appendix B, Criterion XVI requires that measures shall be established to assure conditions adverse to quality, such as
- failures, malfunctions, deficiencies, deviations, and non-conformances are properly identified and corrected.
The licensee's Corporate Quality Assurance
- Manual, Paragraph 12.3.1, requires that significant conditions adverse to quality be documented and reported to management.
- Further, the manual requires that corrective actions be determined which will preclude repetition of the condition.
Plant Procedure PLP-002, Corrective Action Program, Section 5.2, requires an Adverse Condition Report (ACR) or other subprogram document be initiated for identified deficiencies.
Contrary to the above, As of February 28,
- 1992, corrective actions in response to a
May 1991, violation regarding the failure of plant drawings to.reflect system modifications, were not adequate in that plant drawings did not reflect modifications to the Component Cooling Water (CCW) system affecting heat exchanger relief valves in November and December, 1991.
Corrective actions for the May 1991, drawing violation, which included a
quarterly audit review process to ensure that drawings are properly annotated to reflect design
- changes, were not implemented in that the drawings were not audited in the required time period.
On February 20,
- 1992, an ACR was not generated as required by Procedure PLP-002, to document an identified deficiency'n the.control room emergency ventilation system.
The deficiency prevented the system from adequately pressurizing the control
- room, however, the systems'imiting Condition for operation was not exceeded.
This is a Severity Level IV Violation (Supplement I).
Denial or Admission and Reason for the Violation:
The violation is admitted.
(Example 1)
On February 28,
- 1992, it was noted by the inspector that plant drawings 2165-S-1320 and 2165-S-1322 were not properly annotated to document recent CCW system modifications.
After a modification has been worked in the field part of the turnover process is. the delivery to Operations of "redlined" marked up drawings to show what was changed by the modification.
These drawings are filed for reference and the appropriate drawings and aperture cards are annotated with the Plant Change Request (PCR) number to alert Operations personnel to consult the PCR while using the drawing.
When the drawing changes, MEM/HO-920085/2/OS1
ttachment to NRC-781 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-04 (continued) which are carried as exceptions to the PCR closeout, are completed, a new drawing revision is issued.
The problem noted by the inspector was caused by a
misunderstanding on the part of some of the Operations Production Assistants (PAs) who do the drawing annotation.
They believed that new drawing revisions cleared all outstanding PCR's and would thus have no redline annotations as issued.
Due to the time delay in processing drawing changes this is not correct.
(Example 2)
As part of CP&Ls corrective action to the May.1991 violation on drawing annotation an audit process was to be implemented by July 26, 1991.
Procedure OMM-014, Operation, of the Clearance Center was revised to require the audit.
- However, guidance on how the audits were to be scheduled, accomplished and documented was not proceduralized nor conveyed to the responsible PAs.
(Example 3)
One train of the Control Room Area Ventilation System (CRAVS) emergency filtration (R-2B) Unit was found to have a door not completely shut.
With the door not shut the unit would not pressurize the Control Room when placed in the recirculation mode.
Upon. closing the R-2B Unit door adequate pressurization was achieved.
It is believed that the door was opened and not properly shut during routine rounds by Operations personnel.
Operations personnel failed to recognize the need to initiate an ACR concerning this matter.
Corrective Ste s Taken and Results Achieved:
(Examples 1&2)
A review of drawings assigned to Operations was conducted.
Additional discrepancies were identified and also corrected.
(Example 3)
ACR 92-068 was generated on February 26, 1992.
Instructions were issued to appropriate Operations personnel describing, the problem and stating that the door to the R-2 units are not to be opened during routine rounds.
This instruction will be added to the Rounds Guidance which outlines the equipmen" checks necessary for Operations rounds.
Corrective Ste s Taken to Avoid Further Violations:
(Examples 1&2)
Procedure OMM-014 will be revised to include specific guidance on drawing revisions and annotations.
The revision will include specific guidance on the performance and documentation of the drawing audits.
The required drawing audits will be placed on an appropriate scheduling system.
Training will be provided to the PAs on the process for ensuring drawings accurately reflect current modification status and on the performance of the required audits.
(Example 3)
The issue of failing to document identified deficiencies willbe included in the "Required Reading" for the operating staff to emphasis the need for closer attention in this area.
MEM/HO-920085/3/Osl
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-04, (continued)
Date When Full Com liance Will Be Achieved:
Full compliance will be achieved by June 30, 1992.
VIOLATION 400 92-04-02 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, 1978.
Regulatory Guide 1.33, Appendix A, Paragraph 8,
requires procedures for test activities.
Engineering Periodic Test procedures EPT-183, 1CS-744 Alternate MiniflowRelief Valve Relief Pressure Test; and EPT-184, 1CS-755 Alternate MiniflowRelief Valve Relief Pressure Test, require an independent verification be performed to ensure that system valves have been returned to their required positions.
Plant Procedure PLP-702, Independent Verification, specifies that qualified individuals are to perform independent verifications.
Contrary to the above, on February 21, 1992, during performances of EPT-183 and EPT-184, a qualified individual was not used to independently verify steps to return the system to operational status.
This is a Severity Level IV Violation (Supplement I).
Denial or Admission and Reason for the Violation:
The violation is admitted.
Procedure PLP-702 states that qualified personnel assigned the responsibility of performing the testing, maintenance or operating procedure as designated by their foreman may perform an independent verification.
This description matches closely with that of a System Engineer who performed the independent verification in this case.
When the NRC inspector questioned the System Engineer as to his qualification to sign off the independent verification of system restoration the System Engineer stated that it was his belief that he was qualified.
Subsequent consultation with the System Engineers'upervisor revealed that he was not qualified.
TMM-100, Technical Support Conduct of Operations, does not provide guidance concerning the performance of independent verification by System Engineers.
MEM/HO-920085/4/OS1
Attachment to NRC-781 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-04 (continued)
Corrective Ste s Taken and Results Achieved:
Proper valve positions were reverified by qualified Operations personnel.
Technical Support personnel were promptly notified verbally and in the form of a memorandum not to perform independent verification for any procedure steps involving system initial lineup or restoration until further-notice.
Corrective Ste s Taken to Prevent Further Violations:
Procedure TMM-100 will be revised to define Technical Support activities and responsibilities with regard to independent verification.
Date When Full Com liance Will Be Achieved:
Full compliance will be achieved by June 1,
1992.
MEM/HO-920085/5/OS1
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