ML18012A793

Responds to NRC 970424 Ltr Re Violations Noted in Insp Rept 50-400/97-03.Corrective Actions:Submitted LER 97-005-00 on 970317 & Reviewed Violation W/Individuals Involved to Ensure Understanding Re Identification of Reportable Conditions

ML18012A793
Person / Time
Site:	Harris
Issue date:	05/26/1997
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-400-97-03, 50-400-97-3, HNP-97-104, NUDOCS 9706020132
Download: ML18012A793 (6)

Text

CATEGORY j.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESBION NBR 9706020132 DOC. DATE: 97/05/26 NOTAR I ZED: NO DOCKET 0 FAC I L: 50-400 Shearon Harris Nuclear Poeer Plant. Unit 1 Carolina ~ 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON. W. R Carolina Power 5 Light Co.

REC IP. NAME RECIPIENT AFFILIATlON Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 970424 ltr re violations noted in insp rept 50-400/97-03. C o rr e c t i ve actions: submitted LER 97-005-00 on 970317 9~ revieeed violation 0j/individuals involved to ensure understanding re indentification of reportable conditions.

DISTRIBUTION CODE: IEQ1D COPIES RECEIVED: LTR 'NCL SIZE:

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

NOTES:Application for permit reneeal filed. 0'5000400 G

REC IP I ENT COPIES RECIPIENT COPIES ID CODE/MANE LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 ROONEYs V 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 1 1 DEDRO 1 1 1 1 NRR/DISP/P IPB 1 1 NRR/DRCH/HHFB 1 NRR/DRPM/PECB NRR/DRPM/PERB 1 NUDOCS-ABSTRACT 1 OE D'IR 1 1 OGC/HDS2 1 1 RGN2 F ILE 01 1 1 D

EXTERNAL: LITCO BRYCEi J H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 0 E

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COP IES REQUIRED: L TR 20 ENCL 20

Carolina Power 8 light Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris NUclear Plant MAY 2 6 1997 SERIAL: HNP-97-104 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/I.ICENSE NO. NPF-63 REPLY TO NOTICE OF VIOLATIONS(NRC INSPECTION REPORT NO. 50-400/97-03)

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Dear Sir or Madam:

Attached is Carolina Power & Light Company's reply to the Notice of Violations described in Enclosure 1 of your letter dated April 24, 1997.

Questions regarding this matter may be referred to Ms. D. B. Alexander at (919) 362-3190.

Sincerely, MGW/mgw Attachment c: Mr. J. B. Brady (NRC Senior Resident Inspector, HNP)

Mr. N. B. Le (NRR Project Manager, HNP)

Mr. L. A. Reyes (NRC Regional Administrator, Region II) 9706020132 970526 PDR ADQCK 05000400 8 PDR llllllllllflllllllllll[IIllllllll.lllllll State Road 1134 New Hill NC Tel 919362-2502 Fax 919362.2095

Attachment to HNP-97-104 REPLY TO NOTICE OF VIOLATIONS NRC INSPECTION REPORT NO. 50-400/97-03 Re orted Violation A:

Technical Specification 6.8.1.a requires, in part, that procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, "Quality Assurance Program Requirements (Operations)." Regulatory Guide 1.33, Appendix A, Section 6.p, requires written procedures for combating emergencies and other significant events such as fire in the control room or forced evacuation of the control room.

The Harris Plant Final Safety Analysis Report, Section 7.4, Systems Required for Safe Shutdown, included the motor-driven auxiliary feedwater pumps, the residual heat removal system, and the component cooling water system among those required to bring the plant to safe shutdown. It described these systems as having control capability from the Auxiliary Control Panel (outside the main control room).

Contrary to the above, as of March 29, 1997, the licensee failed to provide procedures for the operation of the motor-driven auxiliary feedwater pumps, the "A" train residual heat removal system, and the "A" train component cooling water system from the Auxiliary Control Panel following a forced evacuation of the main control room.

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

Denial or Admission of Violation:

The violation is admitted.

Reason for the Violation:

The violation occurred due to a misinterpretation in the application of single failure requirements for these safe shutdown systems. During development of Abnormal Operating Procedure AOP-004, Remote Shutdown, system components and train divisions that were included in the Harris Safe Shutdown Analysis were excluded from redundancy and certain single failure requirements with respect to safe shutdown following a fire related control room evacuation. It was not recognized that the motor-driven auxiliary feedwater (AFW) pumps, "A" train residual heat removal (RHR) system, and the "A" train component cooling water (CCW) "system were required to meet single failure redundancy criteria for achieving safe shutdown following control room evacuations unrelated to a fire.

Attachment to HNP-97-104 Corrective Ste s Taken and Results Achieved:

Following the inspector's initial finding regarding the operation of the motor-driven AFW pumps from the ACP, a review of the Harris FSAR Section 7.4, Systems Required for Safe Shutdown, was conducted to determine if there were similar safe shutdown components that were not covered by procedure. The review resulted in the identification of several other components, including the "A"train RHR system, "A"train CCW system, "A"train boric acid transfer pump, "C" train steam generator power operated relief valve, and "A" train charging and safety injection pump, for which procedures were required to address operation from the ACP for safe shutdown with no fire. The procedures described below have been revised as a result of this review.

AOP-004, "Remote Shutdown," Revision 12, was approved on May 15, 1997 which incorporates instructions for operating components required for safe shutdown with no fire.

Operations Surveillance Test Procedure OST-1813, "Remote Shutdown System Operability - 18 Month Interval - Modes 5 or 6," Revision 7 was approved on April 2, 1997 to incorporate testing of components required for safe shutdown with no fire.

Corrective Ste s That Will Be Taken to Prevent Further Violations:

No further actions required.

Date When Full Com liance Was Achieved:

Full compliance was achieved on May 15, 1997, with the completion of the procedure revisions as stated above.

Re orted Violation B:

10 CFR 50.73, requires that a Licensee Event Report be submitted for items subject to the paragraph within 30 days after discovery of the event. Paragraph (a)(2)(i) includes any operation or conditions prohibited by the plant's Technical Specifications.

Contrary to the above, from March 3, 1997 until March 17, 1997, the licensee failed to submit a Licensee Event Report within 30 days of discovery of an operation prohibited by the plant's Technical Specification in that, on January 30, 1997, the licensee was aware that a failure to comply with Technical Specification 3.2.3 had occurred on March 20, 1996. The Licensee Event Report was not submitted until March 17, 1997.

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

Attachment to HNP-97-104 Denial or Admission of Violation:

The violation is admitted.

Reason for the Violation:

The violation occurred due to a failure to clearly establish and communicate the event discovery-date and required 30-day LER due date within the Licensing-Regulatory Programs Unit.

'orrective Ste s Taken and Results Achieved:

LER 97-005-00 was submitted to the NRC on March 17, 1997 reporting the failure to comply with Technical specification 3.2.3.

This violation has been reviewed with the individuals involved to ensure a clear understanding exists related to the identification of reportable conditions and establishment of Licensee Event Report due dates. This action was completed on March 27, 1997.

Corrective Ste s That Will Be Taken to Prevent Further Violations:

No further actions required.

Date When Full Com liance Was Achieved:

Full compliance was achieved on March 17, 1997 with submittal of LER 97-005-00.