ML18011A996

Forwards Response to NRC 950707 Ltr Re Violations Noted in Insp Rept 50-400/95-10.Corrective Actions:Performed Drawing Review & Field Walkdown to Confirm No Discrepancies in a & B PORV Compartments

ML18011A996
Person / Time
Site:	Harris
Issue date:	08/07/1995
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HO-950653, NUDOCS 9508110154
Download: ML18011A996 (6)

Text

PRIORITY 1 (ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

A ION NBR:9508110154 DOC.DATE: 95/08/07 NOTARIZED: NO DOCKET g FA L:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,N.R. Carolina Power & Light Co.

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

SUBJECT:

Forwards response to NRC 950707 ltr re violations noted in insp rept 50-400/95-10.Corrective actions:performed drawing revIew & field walkdown to confirm no discrepancies in "Aii

& "B" PORV compartments.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response I

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 INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/SPD/RAB 1 1 AEOD 1 1 DEDRO 1 1 ~FILE CENTE 1 1 NRR/DISP/PIPB 1 1 /OEAB 1 1 NRR/DRCH/HHFB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN2 FILE 01 1 1 EXTERNAL LI TCO BRYCE i J H 1 1 NOAC NRC PDR 1 1 C

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D8 (415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

Carolina Power 8 Light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant AUG -7 1995 File: H0-950653 Serial: HNP-95-071 10 CFR 2.201 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REPLY TO NOTICE OF VIOLATIONS (NRC INSPECTION REPORT NO. 50-400/95-10)

Gentlemen:

Attached is Carolina Power & Light Company's reply to the Notice of Violations described in of your letter dated July 7,1995.

Questions regarding this matter may be referred to Mr. T. D. Walt at (919) 362-2711.

Sincerely, MV Attachment c: Mr. S. D. Ebneter (NRC-RII)

Mr. S. A. Elrod (NRC-SHNPP)

Mr. N. B. Le (NRR) 9508l10i54 950807 PDR ADQCK 05000400 gp 9 PDR State Road 1134 New Hill NC Tel 919362-2502 Fax 919362-2095

Attachment to HNP-95-071 Page 1 of 3 REPLY TO NOTICE OF VIOLATIONS NRC INSPECTION REPORT NO. 50-400/95-10 Technical Specification 3.6.3 LIMITINGCONDITION FOR OPERATION requires that each containment isolation valve specified in the Technical Specification Equipment List Program, plant procedure PLP-106, shall be OPERABLE with isolation times less than or equal to required isolation times.

It further requires that with one or more of the containment isolation valves inoperable, maintain at least one isolation valve OPERABLE in each affected penetration that is open and take certain additional actions.

Contrary to the above, on May 24-25, 1995, containment isolation valve 1MS-62 was inoperable for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> with a blown fuse in its hydraulic pump controls. During that time plant personnel did not perform the actions required by Technical Specification 3.6.3.

This is a severity Level IV violation (Supplement I)

The violation is admitted.

This condition was caused by inadequate design configuration control during the installation of a plant modification (DCN 251-595), implemented in November 1985, which resulted in a discrepancy between the circuit wiring and the associated wiring diagrams for the 1MS-62 control board alarm. Thus, the design configuration for the 1MS-62 control board alarm circuit was not properly maintained, which resulted in the as-built configuration not matching the design as specified. A contributing cause was the wrong assumptions made by the auxiliary operator when the condition was identified and by the shift supervisor-designee (SSD) during his review. It is, however, important to note that due to the inaccurate design, had the SSD conducted additional research into the applicable wiring diagrams on May 24, 1994, without field trouble shooting,'e would have come to the same conclusion that was made based on the lack of the control board annunciator.

This event/condition was reported to the NRC on June 23, 1995 via Licensee Event Report

¹95-004.

1. A drawing review and field walkdown were performed to confirm no discrepancies in the "A" and "B" Power Operated Relief Valves (PORV) compartments.

The cubicle type installed in Motor Control Center (MCC) 1A31-SA-14D is a type B07.

A review was performed of Equipment Specifications, Vendor Drawings and Control Wiring Drawings (CWDs) for cubicles containing this same cubicle type. A total of four type B07 cubicles were identified. No problems were identified in the remaining three cubicles.

0 Attachment to HNP-95-071 Page 2 of 3 3.~ Identified cubicle types with remote shutdown capability which includes two alarm circuits, two control power fuses, and a blue continuity indicating light that was used in

~

safety related applications and verified the CWDs reflected these features.

Performed a field walkdown of safety related MCCs with the exception of 1A22-SA and 1B22-SB (these MCCs only contain containment fan cooler circuits) and identified those cubicles which have remote shutdown capabilities by observing the existence of a blue light on the cubicle door. One cubicle discrepancy was identified with cubicle 1B21-SB 1E. The Vendor Drawing indicates a remote shutdown feature utilized by this cubicle.

The CWD, which correctly shows the installed breaker type, indicates there is no remote shutdown feature. An Engineering Service Request (ESR) has been initiated to correct the Vendor Drawing reference on the CWD and to correct two unused terminal location numbers.

ESR 95-0568 was completed to correct the wiring discrepancy associated with 1MS-62 on July 6, 1995.

6. ESR 95-0600 was completed to correct the drawing deficiency associated with circuit 1B21-SB 1E on August 3, 1995.

In addition to the above listed completed corrective actions, training for appropriate operations personnel on this event will be completed by August 28, 1995.

August 28, 1995 upon completion of the above training.

TS 6.8.1.a requires procedures recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978, "Quality Assurance Program Requirements (Operation)," be established, implemented, and maintained. Regulatory Guide 1.33 Section 10 includes chemical and radiochemical control procedures prescribing the limitations on concentrations of agents that may cause corrosive attack or fouling of heat transfer surfaces or that may become sources of radiation hazards due to activation. This requirement was further implemented by procedure AP-501, Revision 8, Plant Chemical and Consumable Controls, and associated fact sheet AP-501-00565, Revision 4, [Lubricant, Antisieze, part number 733-079-66]. This fact sheet stated that the material was not to contact reactor coolant, and that it was to be used as a lubricant for metal-to-metal contact in various primary and secondary system components.

Contrary to the above, on May 10, 1995, the licensee failed to implement procedure AP-501, Revision 8, and associated fact sheet AP-501-00565, Revision 4, in that procedure MMM-017, Revision 1, Valve Packing Reference Manual, did not implement the program requirements of AP-501. It directed the use of the subject type material as a packing lubricant, not a metal-to-metal application, in valves with a wide variety of applications, which included valves with reactor coolant inside. Mechanics, while following procedure MMM-017, used the subject material as

Attachment to HNP-95-071 Page 3 of 3 a pacifying lubricant on charging flow control valve 1CS-231, which has reactor coolant flowing through it during reactor operation, thus placing the subject material in contact with reactor coolant.

This is a severity Level IV violation (Supplement I)

The violation is admitted.

During revisions to procedure MMM-017, the AP-501 fact sheets for Chesterton 772 antiseize lubrication were not reviewed to determine and incorporate appropriate material use requirements.

A review was performed via ESR 950572 and ESR 950582, to determine the proper use of Chesterton 772 antisieze lubrication and its equivalent, Fel-Pro N5000. These ESR's determined that both lubricants were acceptable for the application described in the violation.

Fact sheets AP-501-00133 and AP-501-00565 were revised to address the ESR resolutions and appropriately dictate material use requirements.

A review of other Maintenance procedures which reference antiseize lubrication was completed to verify consistency with revised fact sheets.

The expectation to review fact sheets and their contained material use requirements during procedure revisions was reinforced via a memorandum to plant procedure writers A memorandum was also issued to Maintenance personnel to emphasize that AP-501 fact sheets should be treated and used like procedures. If an error or conflict is identified in a fact sheet, the user should stop and contact their supervision.

6. An additional procedure sampling v,as performed to determine if other material use conflicts exist between Maintenance procedures and AP-501'fact sheets. This review was completed on August 4, 1995 and identified no additional inconsistencies with AP-501 fact sheets.

As described above, actions have been taken to correct the cited violation. No additional actions are required to avoid further noncompliance.

Compliance was achieved when the incorrect AP-501 fact sheets were revised (as described in step

¹2 above). This action was completed on August 3, 1995.