ML18016A352

Responds to NRC 980217 Ltr Re Violations Noted in Insp Rept 50-400/97-13.Corrective Actions:Justification for Continued Operation Was Generated Along W/Associated Engineering Evaluation

ML18016A352
Person / Time
Site:	Harris
Issue date:	03/19/1998
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-400-97-13, HNP-98-035, HNP-98-35, NUDOCS 9803240216
Download: ML18016A352 (4)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9803240216 DOC.DATE: 98/03/19 NOTARIZED: NO DOCKET ACIL:50-400. Shearon Harris Nuclear 'Power Plant, Unit 1, Carolina 05000400 UTH.NAME AUTHOR AFFILIATION OBINSON,W.R. Carolina Power & Light Co.

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

SUBJECT:

Responds to NRC 980217 ltr re violations noted in insp rept 50/400/97-13.Corrective actions: justification for continued operation was generated along w/associated engineering evaluation.

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 C

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 FLANDERS,S 1 1 INTERNAL: ACRS 2 2 AEOD/S PD/RAB 1 1 A 1 1 DEDRO 1 1 FILE CENTE 1 1 NRR/DRCH/HHFB 1 1 PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 RGN2 FILE 01 .1 1 RNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 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 COPIES REQUIRED: LTTR 19 ENCL 19

' CPHhL Carolina Power 8 Ught Company William R. Robinson PO Box 165 Vice President New Hill NC 27562 Harris Nuclear Plant MAR 19 1998 SERIAL: HNP-9S-035 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 VIOLATION(NRC INSPECTION REPORT NO. 50-400/97-13)

Dear Sir or Madam:

Attached is Carolina Power 0 Light Company's reply to the Notice of Violation described in Enclosure 1 of your letter dated February 17, 199S.

Questions regarding this matter may be referred to Mr. J. H. Eads at (919) 362-2646.

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

Mr. S. C. Flanders (NRR Project Manager, HNP)

Mr. L. A. Reyes (NRC Regional Administrator, Region II) 98032402ib 9803k%

PDR ADOCK 05000400 8 PDR 5413 Shearon Harris Road New Hill NC Tel 919 362-2502 Fax 919 362-2095

Attachment to HNP-98-035 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/97-13 Re orted Violation:

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to ensure that conditions adverse to quality such as deficiencies, deviations, and nonconformances are promptly identified and corrected.

Contrary to the above, prior to January 6, 199S, the licensee failed to adequately correct a design deficiency to the steam generator feedwater preheater bypass line containment isolation valve actuators. These actuators were susceptible to a slow air line leak failure mechanism and corrective actions have not adequately addressed all failure possibilities which could cause this failure to occur.

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

Denial or Admission of Violation:

The violation is admitted.

Reason for the Violation:

The failure to adequately correct the design deficiency stated above was due to the lack of a clear description in the FSAR of the valve actuator's design and associated failure mode and inadequate design control measures during development of a plant modification implemented in August 1984, which was prior to issuance of the Harris Plant Operating License. Additionally, there were several missed opportunities to identify this deficiency as stated in previously submitted LER 98-001-00, dated February 9, 1998. These missed opportunities included: (1) Harris Nuclear Plant's response development for NRC Generic Letter 88-14 in 19S9, which specifically included an evaluation (Plant Change Request, PCR-4151) of the Instrument Air System and the Pre-heater Bypass Valve actuator design, (2) Adverse Condition Report ¹91-314 initiated in June 1991, which identified a leak in the supply air regulator for 1AF-S1 that significantly lowered accumulator pressure, and (3) development of PCR-6158 and it's associated evaluation (PCR-6066) in 1992, which implemented a modification to the actuator air circuitry to enhance the air intensifier pump and upgrade portions of the control air piping to safety-related. In each of these cases, the "smart" leak scenario described in LER 98-001-00 and the subject of this violation was not identified nor considered credible due to the incorrect assumption that the system design met the single failure design criteria.

Corrective Ste s Taken and Results Achieved:

1. A Justification for Continued Operation (JCO ¹98-01) was generated along with the associated engineering evaluation (ESR ¹9800014). This JCO/evaluation determined that the Pre-heater Bypass Valves remained operable based upon a once per shift (12-hour) monitoring of the discharge pressure on the inlet regulator for each valve actuator to ensure the integrity of the non-safety related instrument air piping.

Attachment to HNP-9S-035 Corrective Ste s Taken and Results Achieved: (continued)

2. The Daily Operations Surveillance Test procedures (OST-1021 and OST-1022) were revised to direct 12-hour monitoring of the discharge pressure on the inlet regulator for each valve actuator.

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

1. A plant modification will be developed and implemented to resolve the smart leak in the non-safety related Instrument Air System header. This will be completed prior to entering Mode-4 following completion of Refueling Outage ¹8, which is currently scheduled to begin in October 1998.

2. The FSAR will be revised to include a description of the modified Steam Generator Pre-heater Bypass Isolation Valves. This will be completed by December 31, 1998.

3. Training will be provided to appropriate Engineering personnel, which addresses the design control aspects of this event. This will be completed by July 15, 1998.

Date When Full Com liance Will Be Achieved:

Full compliance will be achieved by December 31, 199S upon completion of the corrective actions as stated above.