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 B CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-775 NUDOCS 9202270071
Download: ML18010A540 (12)

See also: IR 05000400/1991027

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