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{{#Wiki_filter:ACCELERATED | {{#Wiki_filter:ACCELERATED DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) | ||
DISTRIBUTION | ACCESSION'BR:9202270071 DOC.DATE: 92/02/24 NOTARIZED: NO DOCKET ¹ CIL:50-400 Shearon Harris Nuclear Power'Plant, Unit 1, Carolina 05000400 UTH.NAME AUTHOR AFFILIATION ICHEY,R.B. Carolina Power & Light Co. | ||
DEMONSTPWTION | RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) | ||
SYSTEM REGULATORY | |||
INFORMATION | ==SUBJECT:== | ||
DISTRIBUTION | 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. | ||
SYSTEM (RIDS)ACCESSION'BR:9202270071 | DZSTRZBUTZON CODE: ZEOZD COPZES RECEZVED:LTR i ENCL / SZSE: | ||
DOC.DATE: 92/02/24 NOTARIZED: | TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR' ENCL PD2-1 PD 1 1 MOZAFARI,B. 1 INTERNAL: ACRS 2 2 AEOD 1 l. | ||
NO CIL:50-400 | AEOD/DEIIB 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR HARBUCKgC. 1 1 NRR MORISSEAUiD 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1' NUDOCS-ABSTRACT 1 1 OE DI ' OGC/HDS1 1 1 REGMX.LE - '=-" 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG&G/BRYCEgJ.H. 1 1 NRC PDR 1 l. | ||
Shearon Harris Nuclear Power'Plant, Unit 1, Carolina UTH.NAME AUTHOR AFFILIATION | NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS: | ||
ICHEY,R.B. | PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK. | ||
Carolina Power&Light Co.RECIP.NAME | ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED! | ||
RECIPIENT AFFILIATION | TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24 | ||
Document Control Branch (Document Control Desk) | |||
noted in insp rept 50-400/91-27.Corrective | 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) | ||
actions:comparator | Do'cument Control Desk NRC-775 United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen: | ||
channel selector switch was returned to normal position.DZSTRZBUTZON | 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. | ||
CODE: ZEOZD COPZES RECEZVED:LTR | It is considered that the corrective actions taken/planned are satisfactory for resolution of the violations. | ||
i ENCL/SZSE: TITLE: General (50 Dkt)-Insp Rept/Notice | 'hank you for your consideration in this matter. | ||
of Violation Response NOTES:Application | Very truly yours, A,4~ | ||
for permit renewal filed. | R. B. Richey Vice President Harris Nuclear Project MGW:dmw Attachment cc: Mr. S. D. Ebneter (NRC-RII) | ||
DEDRO NRR MORISSEAUiD | Ms. B. L. Mozafari (NRC) | ||
NRR/DLPQ/ | Mr. J. E. Tedrow (NRC - SHNPP) | ||
NRR/ | MEM/H0-920049.0/1/OS1 yP RGB'"=''.~ 9202270071 920224 PDR ADOCK 05000400 8 PDR | ||
NRR/PMAS/ILRB12 | |||
OE DI | 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 hours 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 | |||
identified | 'RC INSPECTION REPORT NO. 50-400/91-27 (continued) | ||
in Enclosure l.It is considered | Corrective Ste s Taken- To Avoid Further Violations: | ||
that the corrective | This violation is being reviewed with the Operations personnel on-shift at'the | ||
actions taken/planned | , 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 channel selector switch to facilitate easier verification of switchNI'ompaiator position is being evaluated. | ||
are satisfactory | Date When Full Com liance Will Be Achieved: | ||
for resolution | Full compliance will be achieved on February 24, 1992. | ||
of the violations. | VIOLATION 400 91-27-03 Re orted Violation: | ||
'hank you for your consideration | Technical Specification 6.5.4.1 requires that audits of unit activities shall be performed by the Nuclear Assessment Department. These audits shall encompass: | ||
in this matter.Very truly yours, A,4~R.B.Richey Vice President Harris Nuclear Project MGW:dmw Attachment | 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. | |||
cc: Mr.S.D.Ebneter (NRC-RII)Ms.B.L.Mozafari (NRC)Mr.J.E.Tedrow (NRC-SHNPP)MEM/H0-920049.0/1/OS1 | t The training, qualifications, and performance, as a group,. of the entire unit staff, at least once per 12 months. | ||
9202270071 | The'mergency plan and implementing procedures, at least once per 12 months. | ||
920224 PDR ADOCK 05000400 8 PDR | Contrary to the above, as of January 15, 1992, audits of unit activities were not performed in that: | ||
Attachment | An audit was not performed't least once per six months to evaluate the results of actions taken to correct deficiencies. | ||
To NRC-775 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION | 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. | ||
REPORT NO.50-400/91-27 | 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. | ||
VIOLATION 400 91-27-01 Re orted Violation: | MEM/H0-910249.0/3/OS1 | ||
Technical Specification | |||
6.8.l.a requires that written procedures | Attachment To NRC;775 | ||
be established | : i. REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/91-27 (continued) | ||
and implemented | Re orted Violation: (continued) | ||
covering procedures | An audit was not performed at least once per 12 months to evaluate the emergency plan and implementing procedures. | ||
outlined in Appendix A of Regulatory | This is a Severity Level IV violation (Supplement I). | ||
Guide 1.33, Revision 2, February 1978.Regulatory | Denial or Admission and Reason for the Violation: | ||
Guide 1.33, Appendix A, paragraph 5 requires procedures | The violation is admitted. | ||
for responding | 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. | ||
to alarmed conditions. | 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. | ||
Alarm response procedure ARP-ALB-013, Main Control Board,-section | Corrective Ste s Taken and Results Achieved: | ||
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 | 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. | ||
placing the comparator | 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. | ||
channel lower section switch to the appropriate | MEM/H0-910249.0/4/OS1 | ||
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 | i Attachment To NRC-775 i REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. | ||
in the N-42 defeat position.This is a Severity Level IV violation (Supplement | (continued) 50-400/91-27 Corrective Ste s Taken To Prevent Further Violations: | ||
I).Denial or Admission and Reason for the Violation: | 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. | ||
The violation is admitted.On January 13, 1992, the Nuclear Instrumentation (NI)comparator | In this manner, assessments will be completed within Technical Specification required times. | ||
channel selector switch for power range lower detector flux deviation and auto-defeat | Similar reviews and appropriate. corrective action have been taken with respect to Technical Specification requirements at all three s'es. | ||
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 | Date When Full Com liance Will Be Achieved: | ||
due to a downpower maneuver, detector calibration | Full compliance will be achieved on March 13, 1992. | ||
cycle, and fuel cycle characteristics. | Re orted Weakness: | ||
The log indicated"numerous" detector deviation or auto defeat alarms.No alarms wer'e received during the following nightshift. | 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. | ||
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 | ~Res ense: | ||
or the following dayshift (1/13/92). | 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. | ||
The cause of the violation is due to inappropriate | Re orted Weakness: | ||
work practice, in that the switch was inadvertently | 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 function by the inspector that draft audit reports were being distributed to the audited 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. | ||
left in the N-42 position.Corrective | MEM/H0-910249.0/5/OS1 | ||
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 | Attachment To NRC-775 i REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 50-400/91-27 (continued) | ||
test OST-1039, Calculation | R~es ense: | ||
of Quadrant Power Tilt Ratio (QPTR), Weekly Interval Mode 1, was performed on January 12, 1992 and January 13, 1992 which satisfies the requirement | 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. | ||
to calculate QPTR every 12 hours when the comparator | MEM/H0-910249.0/6/OS1 | ||
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 | i}} | ||
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 | |||
channel selector switch to facilitate | |||
easier verification | |||
of | |||
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 | |||
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 | |||
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 | |||
i | |||
}} |
Latest revision as of 21:07, 3 February 2020
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 DOCKET ¹ CIL:50-400 Shearon Harris Nuclear Power'Plant, Unit 1, Carolina 05000400 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. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR' ENCL PD2-1 PD 1 1 MOZAFARI,B. 1 INTERNAL: ACRS 2 2 AEOD 1 l.
AEOD/DEIIB 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR HARBUCKgC. 1 1 NRR MORISSEAUiD 1 1 NRR/DLPQ/LHFBPT 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1' NUDOCS-ABSTRACT 1 1 OE DI ' OGC/HDS1 1 1 REGMX.LE - '=-" 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG&G/BRYCEgJ.H. 1 1 NRC PDR 1 l.
NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.
ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR 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 NRC-775 United States Nuclear Regulatory Commission Washington, DC 20555 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 cc: Mr. S. D. Ebneter (NRC-RII)
Ms. B. L. Mozafari (NRC)
Mr. J. E. Tedrow (NRC - SHNPP)
MEM/H0-920049.0/1/OS1 yP RGB'"=.~ 9202270071 920224 PDR ADOCK 05000400 8 PDR
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 channel selector switch to facilitate easier verification of switchNI'ompaiator 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.
(continued) 50-400/91-27 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 function by the inspector that draft audit reports were being distributed to the audited 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