ML18010B104

Responds to NRC 930506 Ltr Re Violation & Deviation Noted in Insp Rept 50-400/93-08.Corrective Actions:Fuel Pool Cooling Pump QA-SA Placed on Increased Testing Frequency & Maint Procedure MMM-012 Revised

ML18010B104
Person / Time
Site:	Harris
Issue date:	06/03/1993
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-815 HO-930104, NUDOCS 9306070255
Download: ML18010B104 (6)

Text

scen.zm rzo DOnvmm DrSxemm.re SvSrmr REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9306070255 DOC.DATE: 93/06/03 NOTARIZED: NO DOCKET CIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 UTH.NAME AUTHOR AFFILIATION AUGHN,G.E. Carolina Power 6 Light Co.

RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 930506 ltr re violation s deviation noted in Insp Rept 50-400/93-08.Corrective actions:Fuel Pool Cooling Pump QA-SA placed on increased testing frequency 6 Maint Procedure MMM-012 revised.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 LE,N 1 1 D

INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/DSP/TPAB 1 1 AEOD/TTC 1 1 DEDRO 1 1 NRR/DORS/OEAB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRIL/RPEB 1 1 NRR/DRSS/PEPB 1 1 NRR/PMAS/ILPBl 1 1 NRR/PMAS/ILPB2 1 1 NUDOCS-ABSTRACT 1 1 OE DIR~ 1 1 OGC/HDS1 1 1 REG~LE~ 02 1 1 RES MORISSEAU,D 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG&G/BRYCE,J.H. 1 1 NRC PDR 1 1 NSIC 1 1 D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI 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 23 ENCL 23

COAL Carolina Power & Light Company P.O. Box 165 ~ New Hill, NC 27562 G.E.VAUGHN Vice President Harris Nuctear Piant JUN - 3 1993 Letter Number: HO-930104 NRC-815 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION AND DEVIATION Gentlemen:

In reference to your letter of May 6, 1993, referring to NRC Inspection Report RII: 50-400/93-08, the attached is Carolina Power and Light Company's reply to the violation identified in Enclosure 1 and the" deviation identified in Enclosure 2.

It is considered that the attached response is satisfactory for resolution of the items.

Thank you for your consideration in this matter.

G. E. Vaughn Vice President Harris Nuclear Plant MGW:cmg Attachment cc: Mr. S. D. Ebneter (NRC-RII)

Mr. N. B. Le (NRC-NRR)

Mr. J. E. Tedrow (NRC-SHNPP)

Q (O'U9P MEM/MS-930104/1/OS1 9306070255 9'30603 PDR ADOCN 05000400 PDR y OI 8

Attachment to NRC-815 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/93-08 Re orted Violation:

10 CFR 50.55(f) requires operating nuclear power facili'ties to perform inservice testing for ASME Code Class 1, 2 and 3 components in accordance with requirements as set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda.

Inservice Inspection Program Procedure ISI-203, ASME Section XI Pump and Valve Program Plan, presents the licensee's program for inservice testing as set forth in the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWP and IWV, 1983 Edition through the Summer 1993 Addenda. Procedure ISI-203, Section 5.4.3, requires that corrective actions for pumps whose surveillance test data falls within the alert range take the form of increased frequency testing, an analysis, or both.

Contrary to the above, on twelve occasions between February 14, 1990 and December 1992, several Code Class 2 and 3 pumps were not placed on increased testing frequencies or re-analyzed following inservice testing where monitored data had gone into the alert ranges.

This is a Severity Level IV violation (Supplement I).

Denial or Admission:

The violation is admitted.

Reason for the Violation:

The cause for this violation has been determined to be personnel error due to a lack of explicit procedural guidance and a weakness in the existing data entry and analysis software.

On March 12, 1993, data from Surveillance Test OST-1090 was being reviewed and analyzed in accordance with ISI-203, when it was discovered that the Fuel Pool Cooling Pump 1A-SA was in the high alert range for differential pressure. In addition, it was realized that the pump had been in the high alert range since June 23, 1992, but had not been placed on Increased Testing Frequency (ITF) nor had the condition been evaluated.. On March 15, 1993, an adverse condition report (ACR 93-126) was written to document this deviation from ASME XI code

. requirements. The IST Coordinator initiated a limited scope review of test data back to May 1, 1991, to detect similar occurrences. This review revealed no other occurrences. Subsequently the inspector conducted a broader based review which revealed twelve (12) additional occurrences.

MEM/MS-930104/2/OS1

Attachment to NRC-815 REPLY TO A NOTICE OF VIOLATION q NRC INSPECTION REPORT NO. 50-400/93-08 Corrective Ste s Taken and Results Achieved:

The immediate corrective actions taken were as follows:

1) The Fuel Pool Cooling Pump 1A-SA was placed on ITF as required by ISI-203.

2) Written instructions were developed for the data entry and analysis process.

3) Software enhancements were made which provide personnel the ability to view test data on a trend graph which depicts the alert and action limits.

4) Data entry personnel were counseled on this event and were instructed on the new written instructions and software enhancements.

Corrective Ste s Taken to Avoid Further Violations:

To prevent further problems in this area, a new Technical Support Guide is being developed which will contain detailed instructions for data entry and analysis.

ISI-203 will be revised to provide more detailed guidance and reference to the new Technical Support Guide.

Date When Full Com liance Will Be Achieved:

The above corrective steps will be completed by July 9, 1993.

MEM/MS-930104/3/OS1

Attachment to NRC-815 REPLY TO A NOTICE OF DEVIATION NRC INSPECTION REPORT NO. 50-400/93-08 Re orted Deviation:

Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),

Appendix A, paragraph 9.a states that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures.

The Final Safety Analysis Report, paragraph 1.8 describes the extent to which the licensee complies with Regulatory Guide 1.33 and states, in part, that maintenance shall be preplanned and performed in accordance with written procedures except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of plant conditions to a possible unsafe or unstable level.

Contrary to the above, non-emergency safety-related maintenance activities were commenced on March 14, 1993, to troubleshoot the "A" emergency diesel generator control panel without appropriate preplanning.

Reason for the Deviation:

Maintenance Procedure MMM-012, Maintenance Work Control Procedure allows the Shift Supervisor the authority to direct maintenance activities to the responsible Maintenace Supervisor without required reviews (i.e. QA, ISI, etc.),

and without a planned Work Request in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of plant conditions to a possible unsafe or unstable level. The procedure further stated that these activities shall be documented by the Shift Supervisor or his designee by initiation of a priority 1, 2 or 3, Work Request. This Work Request should be planned and any required reviews performed as soon as plant conditions allowed.

The statement that these activities be documented by initiation of a priority 1, 2, or 3 Work Request gave the impression that Work Requests with priorities 2 and 3 which do not meet the criteria of FSAR Section 1.8 for emergency or abnormal conditions, could also be implemented without preplanning if directed by the Shift Supervisor. Evidence of this misunderstanding was noted by the inspector with the implementation without preplanning of Work"Request 93-ACXT1 which was a priority 3.

Corrective Ste s Taken and Results Achieved:

A Night Order was generated on April 20, 1993-, to all Shift Supervisors stating that work would no longer be allowed to start prior to the Work Request being planned and the paperwork in hand except for entry into Technical Specification 3.0.3 or when a plant emergency exists (being in an unanalyzed condition or personnel safety is in immediate danger).

MEM/MS-930104/4/OS1

Attachment to NRC-815 REPLY TO A NOTICE OF DEVIATION NRC INSPECTION REPORT NO. 50-400/93-08 Corrective Ste s Taken to Avoid Further Deviations:

Procedure MMM-012 has been revised to clarify that only priority 1 Work Requests (equivalent to FSAR Section 1.8 criteria) may be implemented without the required preplanning. The MMM-012 revision will be reviewed with appropriate maintenance personnel in Real Time Training. The MMM 012 revision will be covered in Required Reading for Operations and Radwaste Shift Supervisors.

Date When Corrective Actions Will Be Com leted:

The above corrective actions will be completed by July 2, 1993.

MEM/HS-930104/5/OS1