ML20138P553
| ML20138P553 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/13/1985 |
| From: | Joseph Willis CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-406 NUDOCS 8512260163 | |
| Download: ML20138P553 (3) | |
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.,t CD&L Carolina Power & Light Companplh c
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HARRIS NUCLEAR PROJECT P. O. Box 165 New Hill, North Carolina 27562 OEC 131985 Flie Numbert SHF/10-13510 NRC-406 Letter Numbert H0-850478 (0)
Dr. J. Nelson Crace United States Nuclear Regulatory Commission Region II
, /y 101 Marietta Street, Northwest (Suite 2900)
H Dear Dr. Gracet In reference to your letter of November 14, 1985 and Inspection Report RIII MDH 50-400/85-39, the attached is Carolina Power and /
Light Company's reply to the violation identified in the inspection report.
It is considered that the corrective action taken is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, 45 Plant Ceneral Manager Shearon Harris Nuclear Power Plant DLT/jsb Attachment cct Messrs. 8. C. Buckley (NRC)
C. Maxwell (NRC-SHNPP)
NBI-OS1 tl 9512260163 951213
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PDR ADOCK 05000400 0
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>I Attachment to CP&L Letter of Response to NRC Report RII: MDH 50-C 400/85-39-01 Reported Violation:
N 10 CPR 50.54(a)(1) requires the licensee to implement the quality assurance program described or referenced in its Safety Analysis
,y Report. Section 17.2.5 states that the SHNPP QA Program establishes the requirements for prescribing and accomplishment of activities affecting quality in accordance with instruction, procedures, and/or drawings. Maintenance Procedure MMM-Oll, Section 5.3 requires open pipe ends to be sealed unless required for operations.
Contrary to the above, (A) open temporary instrument sensing lines
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were found connected to the manifold valves for Flow Transmitters Nos. FT-1SI-940S and FT-1SI-943S and, (B) the instrument air lines k p/
to valves 3CC-L1-SA and 3CC-L2-SB were found disconnected at J i',
several places and open to atmosphere.
P This'is a Severity Level V violation (Supplement II).
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i Denial or Admission and Reason for the Violation:
The violation is correct as stated.
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(A) The temporary instrument sensing lines found connected to the f
manifold valves for Flow Transmitters Nos. FT-1SI-940S and j
FT-1SI-943S were installed to facilitate connecting temporary F
test gauges to support preoperational testing. The l
Installation and removal of the temporary tubing and delta-pressure gauges was performed by Maintenance personnel using l
a Work Request and Authorization Form (WR&A). Upon removal 4
l of the subject test gauges for recalibration and verification p5 the temporary tubing remained in place to support further testing and was inadvertently left uncapped.
f (B) The instrument air lines to valves 3CC-L1-SA and 3CC-L2-SB were disconnected to perform tubing and electrical modifications to the subject air operated valves. This work l,
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was authorized by a Construction Work Authorization Request
, [..j (CWR&A).
Investigation into the problem indicates that the
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- tubing modifications were completed by construction Instrumentation personnel, but the electrical connections i
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7 were not completed to the solenoid operated valves.
In order to operate the Component Cooling Water System valves to support start-up testing in progress, the new air supply tubing was temporarily disconnected to run an air supply to the old solenoids.
In the process, the new air supply tubing was inadvertently left open ended.
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s Corrective Steps Taken and Results Achieved =
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(A)iThe temporary tubing has_been removed, the temporary test
-connection-flushed, and the test connection plugged'with a suitable stainless steel pipe plug.
.(B) The'subjectvalveshavenow[been'permanentlytubedandwired.
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's uCorrective Steps Taken to Avoid Further Noncompliance:
-(A): The' applicable Start-Up. personnel have been reinstructed to comply with good work practices concerning test equipment in-general and open ended tubing and piping specifically.-- I&C LMaintenance craft are being reinstructed in the requirements
.of Section 5.3 of Maintenance Procedure MMM-011.
Section 5.3 requires that openings and pipe ends.be sealed at all times unless they must be unsealed to carry out necessary p
~ operations. This reinstruction is projected to be complete
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by December 31,_1985.?-
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- (B){l Start-Uppersonnelhvebeeninstructedthatbeforeclosinga
~CWR&A,. verify.al1 york covered on the CWR&A has been q: '
~ performed, equipment has been left as designed, and no open tubing connections exist.
L Date When Full' Compliance Will Be Achieved:
Full compliance will be achieved by December.31,'1985.
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