ML18010A823
| ML18010A823 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/19/1992 |
| From: | Vaughn G CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-790 HO-920139, NUDOCS 9210220132 | |
| Download: ML18010A823 (9) | |
Text
accsc~z~ j.'su o>s'ra.raurrOw DziWOxsra.~rrOw Svsrz~vr REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) 05000400 ES~ION'NBR:9210220132 DOC.DATE: 92/10/19 NOTARIZED: NO DOCKET I
CIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION VAUGHNiG.E.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT 'AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 920917 ltr re violations noted in insp rept 50-400/92-15.Corrective actions:handling limitations for new
& irradiated fuel inserts, will be revised specifically to describe handling requirements for new fuel inserts.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.
RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC
'RR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDSl RGN2 FILE 01 EXTERNAL: EG&G/BRYCEgJ.H.
NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME LE,N AEOD AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ILRB12 OE~ILE 02 NRC PDR COPIES LTTR ENCL 1
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1 NOTE TO ALL RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
J
G. E. VAUGHN Vice President Harris Nodear Project OCT 1
9 1992 Letter Number:
HO-920139 CARL Carolina Power & Light Company P.O. Box 165 ~ New Hilt, NC 27562 HARRIS NUCLEAR PROJECT P.O.
Box 165 New'ill, NC 27562 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-790 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:
In refere nce to your letter of September 17, 1992, referring to NRC Inspection Report RII:
50-400/92-15, the attached is Carolina Power and Light Company's reply to the notice of violation identified in Enclosure 1.
It is considered that the corrective actions taken/planned are satisfactory for resolution of the violation.
Thank you for your consideration in this matter.
Very truly yours, MGW:kls Attachment Vice President Harris Nuclear Project cc:
Mr. S.
D. Ebneter (NRC-RII)
Mr. N. B. Le (NRC-NRR)
Mr. J.
E. Tedrow (NRC-,SHNPP) 9210220132 921019 PDR ADDCK 05000000 8
PDR MEM/HO-920139/1/Osl
+po~
Attachment to NRC-790 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-15 VIOLATION 400 92-15-01 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, 1978.
Regulatory Guide 1.33, Appendix A, paragraphs 2 and 3, requires procedures for refueling preparations and for operation of the chemical and volume control system.
Refueling procedure FMP-106, New Fuel Receipt Inspection, Section 6.3, specifies that wet annular burnable absorber inserts be handled using a flexible strap attached to the assembly handling tool T-bar.
Operating procedure OP-107, Chemical and Volume Control
- System, Section 8.8, specifies that the bypass valve be opened prior to backflushing the reactor coolant pump seal return filter.
Contrary to the above, On August 7,
- 1992, the bypass valve was not opened to allow backflushing of the seal return filter which allowed the system flow to be isolated and system pressure increased, which challenged a seal return relief valve.
1.
On July '30,
- 1992, a flexible strap was not utilized to handle the wet annular burnable absorber inserts during inspection.
r 2.
This is a Severity Level IV violation (Supplement I).
Denial or Admission:
The violation is admitted.
Reason for the Violation:
(Example 1)
At 13:45 on July 30,
- 1992, Operations and Technical Support personnel began inspection of the new fuel inserts.
Operations located a flexible strap to use as instructed by the Technical Support Reactor Engineer.
The strap was put on the new fuel insert (by lifting the insert slightly by hand to slip the strap through the T-bar) and the auxiliary crane was used to liftit up for inspection.
The new fuel inserts weigh approximately 30 pounds and personnel decided it would be safer and more efficient to liftthe inserts by hand since the procedure took less than 1 minute per insert to perform.'
Operations personnel utilized procedure FHP-003, Unpacking and Handling of New Fuel Assemblies, Fuel Inserts, and New Fuel'hipping Containers, to unpack and handle the new fuel assemblies.
Although FHP-003 references FMP-106, a Technical Support procedure, for the inspection, Operations personnel assisting with the inspection were not aware of the handling requirements of FMP-106 to use a
flexible strap.
MEM/HO-920139/2/OS1
Attachment to NRC-790 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-15 (continued)
Reason for the Violation: (continued)
(Example')
At 02:45 on August 7, 1992, the Radwaste (RW) operators requested permission from the Main Control Room (MCR) to backflush the Reactor Coolant Pump (RCP)
Seal Return Filter.
The MCR operator granted permission to backflush the filter prior to ensuring that the Seal Return Filter Bypass valve was opened as required by OP-107.
The RW operator commenced the backflush operation in accordance with OP-120.02.39, Fuel Handling Building and Reactor Auxiliary Building Filter Backflush, by closing the filter inlet and outlet isolation valves.
The RW operator almost immediately received the Seal Water Return High AP alarm, coincident with a MCR B
RCP Seal Return Low Flow alarm, and the RW operator immediately opened the filter inlet and outlet isolation valves and notified the MCR.
The MCR and RW determined that the Seal Return Filter Bypass valve needed to be opened and that procedure OP-107 contained directions for opening the filter bypass valve.
The root cause of this violation is attributed to the MCR Operator not being familiar with the section of OP-107 that covered the MCR.actions for filter backwashes.
Corrective Ste s Taken and Results Achieved:
(Example 1)
The failure to follow procedure FMP-106 was not identified until after the insert inspections were successfully completed.
Although a
procedure violation
- occurred, the failure to use a flexible 'strap did not adversely impact the inspection evolution.
(Example 2)
Following discussions between RW and the MCR concerning the need to open the filter bypass valve prior to initiating the filter backflush, the backflush evolution was initiated and completed without further incident.
Corrective Ste s Taken to Avoid Further Violations:
(Example 1)
Fuel Handling Procedures FHP-003 and FHP-002, Handling Limitations for New and Irradiated Fuel Inserts, will be revised to specifically describe the handling requirements for new fuel inserts prior to receipt of new fuel for Cycle 6.
Training will be provided for Operations personnel prior to the handling of new fuel inserts.
MEM/HO-920139/3/Osl
Attachment to NRC-790 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/92-15 (continued)
Corrective Ste s Taken to Avoid Further Violations: (continued)
(Example 2)
An Operations Night Order was issued on August 17, 1992, to inform MCR operations-shift personnel of the incident.
The incident has been reviewed with the individual operator involved.
This review included a review of the applicable steps in OP-107 that address the backflush of the seal return filter.
Several filters require interaction between the MCR and the RW Control Room to complete the filter backwash cycle.
As an additional. measure, RW'rocedure OP-120.02.39 has been changed to identify the action required by the MCR, for
- example, open 1CS-302, Seal Water Return Filter Bypass Valve.
This second check will ensure the appropriate action has occurred prior to initiating the filter backwash.
Date When Full Com liance Will Be Achieved:
(Example 1)
Full compliance is pending revision to FHP-002 and FHP-003 and associated
~
~
training as stated above.
This action will be completed by December 31, 1993.
(Example 2)
Full compliance was achieved on October 19, 1992.
MEM/HO-920139/4/Osl