ML18010A540

Responds to NRC 920124 Ltr Re Violations Noted in Insp Rept 50-400/91-27.Corrective Actions:Comparator Channel Selector Switch Was Returned to Normal Position

ML18010A540
Person / Time
Site:	Harris
Issue date:	02/24/1992
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-775 NUDOCS 9202270071
Download: ML18010A540 (12)

Text

ACCELERATED DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)ACCESSION'BR:9202270071 DOC.DATE: 92/02/24 NOTARIZED:

NO CIL:50-400 Shearon Harris Nuclear Power'Plant, Unit 1, Carolina UTH.NAME AUTHOR AFFILIATION ICHEY,R.B.

Carolina Power&Light Co.RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk).

SUBJECT:

Responds to NRC 920124 ltr re violations noted in insp rept 50-400/91-27.Corrective actions:comparator channel selector switch was returned to normal position.DZSTRZBUTZON CODE: ZEOZD COPZES RECEZVED:LTR i ENCL/SZSE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed.DOCKET¹05000400 05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE DI REGMX.LE-'=-" 02 EXTERNAL: EG&G/BRYCEgJ.H.

NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 RECIPIENT ID CODE/NAME MOZAFARI,B.

AEOD AEOD/DSP/TPAB NRR HARBUCKgC.

NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1'1 l.1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1l.NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

Carolina Power&Light Company P.O.8ox 165~New Hill, N.C.27562 R.8.RICHEY Vice President Harrts Nuclear Project FEB 2 4 f992 Letter Number: HO-920049 (0)Do'cument Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-775 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400 LICENSE NO.NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In reference to your letter of January 24, 1992, referring to NRC Inspection Report RII: 50-400/91-27, the attached is Carolina Power and Light Company's reply to the violations identified in Enclosure l.It is considered that the corrective actions taken/planned are satisfactory for resolution of the violations.

'hank you for your consideration in this matter.Very truly yours, A,4~R.B.Richey Vice President Harris Nuclear Project MGW:dmw Attachment RGB'"=.~

cc: Mr.S.D.Ebneter (NRC-RII)Ms.B.L.Mozafari (NRC)Mr.J.E.Tedrow (NRC-SHNPP)MEM/H0-920049.0/1/OS1 9202270071 920224 PDR ADOCK 05000400 8 PDR yP Attachment To NRC-775 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO.50-400/91-27 VIOLATION 400 91-27-01 Re orted Violation:

Technical Specification 6.8.l.a requires that written procedures be established and implemented covering procedures outlined in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.Regulatory Guide 1.33, Appendix A, paragraph 5 requires procedures for responding to alarmed conditions.

Alarm response procedure ARP-ALB-013, Main Control Board,-section ALB-013-5-4, directs the operator to try and reset the power range lower detector high flux deviation or auto defeat alarm by momentarily placing the comparator channel lower section switch to the appropriate position and then return it to the normal~position.Contrary to the above, on January 13, 1992, the comparator channel lower section switch was not returned to the normal position following an attempt to reset the alarm but was instead found to be positioned in the N-42 defeat position.This is a Severity Level IV violation (Supplement I).Denial or Admission and Reason for the Violation:

The violation is admitted.On January 13, 1992, the Nuclear Instrumentation (NI)comparator channel selector switch for power range lower detector flux deviation and auto-defeat was found in the N-42 position.The last operation of this switch was logged on January 12, 1992 on the dayshift.The alarm was being received frequently due to a downpower maneuver, detector calibration cycle, and fuel cycle characteristics.

The log indicated"numerous" detector deviation or auto defeat alarms.No alarms wer'e received during the following nightshift.

This indicates a failure to return the switch to the normal position after proper alarm response on the dayshift on January 12, 1992.The switch position was not noted at the turnover for nightshift or the following dayshift (1/13/92).

The cause of the violation is due to inappropriate work practice, in that the switch was inadvertently left in the N-42 position.Corrective Ste s Taken and Results Achieved: Upon discovery of this error on January 13, 1992, the comparator channel selector switch was returned to the normal position.Surveillance test OST-1039, Calculation of Quadrant Power Tilt Ratio (QPTR), Weekly Interval Mode 1, was performed on January 12, 1992 and January 13, 1992 which satisfies the requirement to calculate QPTR every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the comparator channel selector switch is not in the normal position.Therefore, adequate control of the QPTR was maintained during this period.MEM/H0-910249.0/2/OS1

Attachment To NRC-775 REPLY TO A NOTICE OF VIOLATION'RC INSPECTION REPORT NO.50-400/91-27 (continued)

Corrective Ste s Taken-To Avoid Further Violations:

This violation is being reviewed with the Operations personnel on-shift at'the , time the switch was inadvertently left in the N-42 position as well as the remaining active shift Operations personnel.

Self-verification of switch positioning and thorough turnover walkdowns will be stressed.,Marking

'of the NI'ompaiator channel selector switch to facilitate easier verification of switch position is being evaluated.

Date When Full Com liance Will Be Achieved: Full compliance will be achieved on February 24, 1992.VIOLATION 400 91-27-03 Re orted Violation:

Technical Specification 6.5.4.1 requires that audits of unit activities shall be performed by the Nuclear Assessment Department.

These audits shall encompass:

The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems, o'r method of operation that affect nuclear safety, at least once per six months.The conformance of unit operation to provisions contained within the technical specifications and applicable license conditions, at least once per 12 months.t The training, qualifications, and performance, as a group,.of the entire unit staff, at least once per 12 months.The'mergency plan and implementing procedures, at least once per 12 months.Contrary to the above, as of January 15, 1992, audits of unit activities were not performed in that: An audit was not performed't least once per six months to evaluate the results of actions taken to correct deficiencies.

An audit was not performed at least once per 12 months to evaluate the conformance of unit operation to provisions contained within technical specifications and applicable license conditions.

An audit was not performed at least once per 12 months to evaluate the training, qualifications, and performance as a group, of the entire unit staff.MEM/H0-910249.0/3/OS1 Attachment To NRC;775 i.REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO.50-400/91-27 (continued)

Re orted Violation: (continued)

An audit was not performed at least once per 12 months to evaluate the emergency plan and implementing procedures.

This is a Severity Level IV violation (Supplement I).Denial or Admission and Reason for the Violation:

The violation is admitted.Nuclear Assessment Department (NAD)Guidelines improperly interpreted the assessment frequency interval requirements contained in the Technical Specifications.

Specifically, the Guideline required that assessments start within the frequency interval defined in the Technical Specifications, and also provided that an assessment start date could be extended by up to 25%of the frequency interval.The expectation was that the extension would not be routinely used but was available to help with manpower/resource allocation.

The guideline also required that, if any extension was used, the subsequent assessments would be started on a frequency based on the original start date, thereby eliminating the potential for cumulatively extending an assessment start date oyer several assessment intervals.

This interpretation of Technical-Specification requirements contained in NAD Guidelines was in error.A review of the NAD assessment records indicates that the assessments cited were conducted within the time limits of established department guidelines, but were completed outside the frequency interval requirements of Technical Specifications.

Corrective Ste s Taken and Results Achieved: A review of assessment records for those assessments required by Technical Specifications was undertaken to determine those assessments which exceeded the standard frequency as defined by the Technical Specifications.

The assessments which fell outside the standard frequency intervals have been completed and line management briefed of the results.The final reports will be forwarded within 30 days of the briefings.

By memorandum dated February 7, 1992, NAD initiated a new policy requiring that assessments be completed, including briefing within the Technical Specification required frequency interval, and that.no extension be applied.This memorandum supersedes the NAD guideline until the guideline is revised to reflect NAD's current policy.MEM/H0-910249.0/4/OS1 i

Attachment To NRC-775 i REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO.50-400/91-27 (continued)

Corrective Ste s Taken To Prevent Further Violations:

The next assessment in each area required by Technical Specifications has been scheduled to be completed prior to one frequency interval from the previous assessment start date.This will ensure that the next assessments are within Technical Specification time intervals.

Once established, assessment frequency intervals will be determined from the debriefing date of the previous assessment.

In this manner, assessments will be completed within Technical Specification required times.Similar reviews and appropriate.

corrective action have been taken with respect to Technical Specification requirements at all three s'es.Date When Full Com liance Will Be Achieved: Full compliance will be achieved on March 13, 1992.Re orted Weakness: TS 6.5.4.4 requires that audit reports encompassed by TS 6.5.4.1 shall be forwarded to various management positions within 30 days after completion of the audit.The Operations audit required by TS 6.5.4.l.a was completed on December ll, 1991.The Operations manager did not receive the Operations audit until January 14, 1992, which exceeded the 30-day time requirement.

A previous failure to forward audit reports within 30 days was identified as a violation (400/91-18-02).

The tardiness in forwarding, this Operations audit indicates that this process is still not performed adequately, and the forwarding process is considered to be weak.~Res ense: As stated, the Operations assessment

'was completed on December 11, 1991.With that completion date, the assessment report was required to be issued and forwarded on or before January 10, 1992.The report was approved and forwarded on January 9, 1992.CP&L uses internal mail routing for such documents and routinely completes distribution within 2-3 days.We believe that signing the report for distribution within 30 days of assessment completion with normal internal mail routing fully meets the 30-day requirement for report issuance.Re orted Weakness: e 10 CFR 50 Appendix B, Part I, requires that organizations performing quality assurance functions shall report to a management level such that organizational freedom is provided.Audit.reports of site activities are used as a quality assurance function to report to corporate management.

It was noted by the inspector that draft audit reports were being distributed to the audited function manager prior to finalization of the audit report and subsequent distribution to corporate management.

This indicates that a lack of organizational freedom exists in the audit program and is, therefore, considered to be a weakness.MEM/H0-910249.0/5/OS1

Attachment To NRC-775 i REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO.50-400/91-27 (continued)

R~es ense: Draft reports may be provided to the audited/assessed function managers to facilitate communications.

Since debriefs are handled orally, this provides line management the first hard copy of the assessment results.Their review is used to help ensure accuracy of the final assessment report and clearer understanding of the results.The content of final assessment reports is independent of line management and remains the responsibility of the Nuclear Assessment Department.

MEM/H0-910249.0/6/OS1 i