ML18012A805
| ML18012A805 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18012A804 | List: |
| References | |
| 50-400-97-04, 50-400-97-4, NUDOCS 9706180248 | |
| Download: ML18012A805 (5) | |
Text
NOTICE OF VIOLATION Carolina Power 8 Light Company Docket No. 50-400 Shearon Harris Unit 1 License No.
NPF-63 During an NRC inspection conducted from March 30 through May 10,
- 1997, violations of NRC requirements were identified.
In accordance with the "General Statement of'olicy and Procedure for NRC Enforcement Actions,"
NUREG-1600, the violations are listed below:
A.
Technical Specification Limiting Condition for Oper ation 3.0.4 requires that entry into an Operational Mode or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained in the Action requirements.
Exceptions to these requirements are stated in the individual specifications.
Procedure GP-009, Refueling Cavity Fill, Refueling and Drain of the Refueling Cavity, Revision 13, implemented this requirement.,
Minimum Equipment List, listed the equipment required for entry into Mode 6 (from defueled) and included both trains of control room ventilation.
Contrary to the above, on May 8, 1997, the licensee failed to meet all Limiting Conditions for Operation required for Mode 6 entry without reliance on action statements in that action (a) for Technical Specification 3.7.6 for control room ventilation was being relied upon due to one train being inoperable and the Limiting'ondition for
'Oper ation did not contain an exception to TS 3.0.4.
This is a Severity Level IV Violation (Supplement I).
B.
10 CFR 50, Appendix B, Criterion XVI requires that measures be established to assure that conditions adverse to quality such as deficiencies, deviations, and nonconformanc'es are promptly identified and corrected.
In the case of significant conditions adverse to uality, the measures shall assure that the cause of the condition is etermined and corrective action taken to preclude repetition.
These requirements are further delineated in Section 12 of the licensee's corporate Quality Assurance Program Manual, Revision 18 and in Administrative Procedure AP-615, Condition Reporting, Revision 20.
Contrary to the above, the licensee failed to take corrective actions for conditions adverse to quality as evidenced by the following:
1.
From November 14, 1996 until March 25,. 1997, the licensee's corrective actions for LER 50-400/96-013-01 to prevent the connecting of the non-seismic qualified component cooling water chemical addition piping section to both trains of the component cooling water system were ineffective to prevent repetition in
. that the event recurred on March 25, 1997.
Enclosure 1
'7706i80248
'F7060'F PDR ADQCK 05000400 6
CPSL 2.
3.
On Harch 29, 1997, the licensee's corrective actions for Violation 50-400/96-09-01 (Refueling Water Storage Tank dilution event) to improve operator performance wer e not effectively implemented to prevent an over-dilution of reactor coolant system boron using the boron thermal regeneration system.
On April 8, 1997, the licensee's corrective actions for Violation 50-400/96-09-01 were not effectively implemented to prevent an
'nadvertent dilution of'eactor coolant system boron using the primary makeup portion of the chemical and volume control system.
This is a Severity Level IV Violation (Supplement I).
C.
Technical Specification 6.8. l.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, "guality Assur ance Program Requirements (Operations)."
Regulatory Guide 1.33, Appendix A, Section 8.b.l.h, requires written procedures for fire protection functional tests.
The Harris Plant Final Safety Analysis Report, Section 9.5.1.2.3; Fire Protection Standpipe and Hose System, states that normally, the post-Safe Shutdown Earthquake standpipe hose station header is supplied from the fire protection water distribution system through seismically qualified check valves.
These check valves perform a fire protection function of preventing backflow and outflow to other portions of the fire protection water distribution system which may have failed during a
seismic event.
FSAR Figure 9.5.1-2 identifies these valves as numbers 3FP-180 and 186; and 1FP-205,
- 218, 2079 and 2080.
Contrary to the above, as of Hay 8, 1997, fire protection surveillance procedures had not been established to verify the functional operability of the seismically qualified fire protection check valves.
This a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U. S.
Nuclear Regulatory Commission, ATTN:
Document Control
- Desk, Washington, D.C.
20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if'ontested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or Enclosure 1
4
CPSL 3
Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Because your response will-be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.
However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the
- PDR, and provide the legal basis to support your request for withholding the information from the public.
Dated at Atlanta, Georgia this 9th day of June 1997 Enclosure 1