ML18009A770
| ML18009A770 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/28/1990 |
| From: | RICHEY R B CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-739 NUDOCS 9101070012 | |
| Download: ML18009A770 (12) | |
See also: IR 05000400/1990021
Text
, ACCELERATED
'ISTRIBUTION
DEMONSTRATION
SYSTEM l R EGULATORY INFORMATXON
DISTRIBUTION
SYSTEM (RIDS)SSION NBR:9101070012
DOC.DATE: 90/12/28 NOTARIZED:
NO IL:50-400 Shearon'Harris
Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION
RICHEY,R.B..
Carolina Power&Light Co.RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)DOCKET 05000400 SUBJECT: Responds to NRC 901130 ltr re violations
noted in Insp Rept 50-400/90-21.Corrective
actions:acid
addition step in Procedure RCP-660"Sample Preparation
for Determination
of Radioactivity" emphasized.
Disagrees w/categorization.
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8E2 NUDOCS-ABSTRACT
OGC/HDS1 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1, 1.1 1'1 1 1 1 1 1 1 1 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24
Carolina Power&Ljght Company P.O.Box t65~New Hill, N.C.27562 R.B.RICHEY Vice President Harris Nuclear Project DEC 2 6,1990 Letter Number.'H0-900206
(0)Doc'ument Control Desk United States Nuclear Regulatory
Commission
Washington, DC 20555 NRC-739 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 November 30, 1990, referring to I.E.Report RII: 50-400/90-21, the attached is Carolina Power and Light Company's reply to the violations
identified
in Enclosure 1.Although the violations
are admitted, Carolina Power and Light Company disagrees with the severity level assigned to violation C.We do not believe'that this identified
violation meets the criteria of a severity level IV as described in 10CFR2 Appendix C, Supplement
I D, and that assignment
of a severity level V is'more appropriate.
This is based on our interpretation
that the violation has no safety or environmental
significance.
I Thank you for your consideration
in this matter.Very truly yours, R.B.Richey Vice President Harris Nuclear Project MGW:mbr Attachment
cc: Mr.R.A.Becker (NRC)Mr.S.D.Ebneter (NRC-RII)Mr.J.E.Tedrow (NRC--SHNPP)9101070012
901228 PDR ADOCK 05000400 9 PDR
e lg'1
Attachment
to CP&L Letter of Res onse to NRC I.E.Re ort RII: 50-400/90-21
Re orted Violation.'.
Technical Specification 6.8.1.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 10, requires that written procedures
be provided for radiochemical
analysis.Radiochemistry
Procedure RCP-660, Sample Preparation
for Determination
of Radioactivity, Steps 10.3.1.2.2
and 10.3.1.1.3, specify that nitric acid be added to the sample prior to the analysis for radioactivity.
Contrary to the above, on October 24 and October 26, 1990, procedure RCP-660 was not properly implemented
in that nitric acid was not added to an"A" Steam Generator sample and a Reactor Coolant System sample, respectively, prior to radioactivity
analysis.This is a Severity Level IV violation (Supplement
I).Denial or Admission and Reason for Violation'.
The violation is correct as stated.On October 24 and again on October 26, 1990, two different Environmental
6 Chemistry (E6C)technicians
were observed by an NRC inspector to not add nitric acid to samples being prepared for activity analysis, as required by RCP-660, Steps 10.3.1.2.2
and 10.1.3.3.The cause of this event was personnel error in that the technicians
failed to follow the procedure.
The technicians
recognize that the purpose for the nitric acid is to serve as a preservative
for samples intended for long-term storage.This is a standard lab practice.The acid helps to avoid plate-out of the activity on the sides of the sample container.
Plate-out could affect the validity of analyses done on samples that have been in storage.Since the individual
samples in question were to be analyzed right away, the technicians
did not perceive the need for any preservative
to be added.Instead the acid was being added to the container used for compositing
the individual
samples for long-term storage.Technically, this is appropriate
but is not consistent
with the exact wording of the procedure.
MEM/HO-9002060/2/OS1
h
'SCorrective
Ste s Taken and Results Achieved: The effect of not adding acid to samples being analyzed right away is"not known but has been assumed to be negligible.
The practice is generally recognized
as applicable
for samples that will be analyzed at some time in the future, but even the significance
of failing to add acid to long-term samples is unknown.To investigate
this, CP6Ls Corporate Radiochemistry
Laboratory
has been requested to perform a study to determine the impact of not adding acid to samples, both long-term and short"term.
Corrective
Ste s Taken to Avoid Further Violations'.
The acid addition step in RCP-660 was emphasized
to EKC technicians
through their"Required Reading" program.Date When Pull Com liance Will Be Achieved: The procedure is now being followed.The study to determine the impact of not adding acid to samples, both long-term and short-term', is expected to be complete by January 31, 1991.The results of the study will determine the necessity of a procedure revision.Re orted Violation.'.
requires, in part, that the licensee shall maintain records of changes in the facility from that'escribed
in the safety analysis report and that these records must include a written safety evaluation
which provides the bases for the determination
that the change does not involve an unreviewed
safety question.j The Final Safety Analysis Report (FSAR)Table 11.1.7-1 lists the design concentrations
of specific activity for various nuclides in the spent fuel pools.Section ll.l.l of the FSAR further states that these maximum activities
have been used in the design basis'for shielding and facilities
design and for calculating
the ,consequences
of postulated
accidents.
Contrary to the above, a sample taken on October 12, 1990, found that the specific activities
of manganese and cobalt in the spent fuel pools exceeded the design concentrations
listed in the FSAR by as much as 5000 times and the licensee failed to provide a written safety evaluation
for an unreviewed
safety question determination.
This is a Severity Level IV violation (Supplement
I).MEM/HO-9002060/3/OS1
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.The shipment of spent fuel from the Brunswick Nuclear Project (BNP)to the Harris Nuclear Project (HNP)has introduced
a large volume of iron oxide crud to the spent fuel pools and transfer canals at HNP.This crud has a loose fluffy layer that is falling off the fuel assemblies
to the floor of the fuel pools and canals.This additional
material has caused the activity of Mn-54 and Co-60 to exceed the values listed in table 11.1.7-1 of the FSAR Section 11.1.7.Exceeding Table 11.1.7-1 values without the required documented
Safety Evaluation
is potentially
a change to the facility as described in the FSAR.There have been (17)seventeen cask loads of spent BWR fuel, consisting
of (18)eighteen assemblies
each, shipped to the HNP from the BNP.These shipments began in July of 1989'and the most recent one was in October of 1990.In January 1990, the Manager (EERC)assessed the potential impact of"crud" and the resulting increase in spent fuel pool activities.
It was concluded that (1)the significant
amount of insoluble particulates
collecting
in the pools should not be allowed to enter the spent fuel skimmer system or else the dose rates around unshielded
components
and piping would become unacceptable, and (2)the nuclide composition
of the"crud" by itself, would not prevent shipment or burial of the material.On this basis, it was recommended
to not utilize the skimmer system for vacuuming the particulate
material from the pools and to investigate
use of alternate filtration
systems for removing and shipping the"crud" for burial.In early 1990 the E6RC Unit evaluated the presence of significant
amounts of crud in the fuel pools to determine if increased dose rates to personnel working in the Fuel Handling Building (FHB)were significant.
The FSAR assumptions
used for estimating
dose rates in the vicinity of the pools were reviewed (FSAR Section 12.3.2.13).
It was concluded that the FSAR analysis considered
the dose rates due to dissolved or suspended radioactivity
to be negligible
compared to that from the spent fuel.After review of this it was decided that no FSAR changes were necessary due to any increase in dissolved or suspended material.In February-March
of 1990, after the position of Manager Spent Nuclear Fuel was established, this manager, a certified Senior Reactor Operator and qualified Safety Reviewer, concluded with respect to FSAR Section 11.1.7 that an increase in fuel pool activity due to crud did not constitute
an unreviewed
safety question.This, however, was an undocumented
management
assessment, not a formal safety revie~.He deemed any increase in pool activity to be primarily an ALARA, and possibly a process system design question.Since the crud problem was under investigation, he decided that an FSAR change would be required but should be delayed until the extent of the problem and the impact of potential solutions was fully understood.
4lEM/HO-9002060/4/OSl
L 0 I'
After documenting
this matter on Significant
Operational
Occurrence
Report (SOOR)$90-148 (October 27, 1990)E&RC reviewed the impact of the crud on the validity of the Technical Specification
setpoint calculations
for the FHB area monitors.It was determined
that elevated general area dose rates tend to make the setpoints more conservative
and thus no changes would be needed.In summary, neither manager required or verified that a formal 10CFR50.59
evaluation
was done nor that a sampling"trigger" was in place to flag when spent fuel pool activities
exceeded Table 11.1.7-1 values.Corrective
Ste s Taken and Results Achieved: Formal 10CFR50.59
evaluations
of the elevated activity levels present in the fuel pools were performed and reviewed by the Plant Nuclear Safety Committee (PNSC).The evaluations
documented
that no unreviewed
safety question'exists.Corrective
Ste s Taken to Avoid Further Violations:
l.An effort is underway to clarify the regulatory
significance
of"descriptive" information
in the FSAR, especially
with respect to what must be reflected and/or monitored in plant procedures
and what comprises"The Facility as Described in the FSAR" for 10CFR50.59
purposes.Once clarification
is obtained, as appropriate, the following actions will be taken: a.Needed revisions will be made to the 50.59 program manual.b.Additional
training for management
and qualified safety reviewers will be conducted.
2.Additional
review of the design basis for the Fuel Handling Building and supporting
systems will be conducted to assess the broader impact of higher than FSAR activities
in the fuel pool water.Date When Full Com liance Will Be Achieved: Full compliance
is expected to be achieved by June 30, 1991, upon completion
of the actions stated above.Re orted Violation:
requires, in part, that the licensee notify the NRC in writing within 30 days of the termination
of any licensed senior operator.Contrary to the above, the NRC was not notified of the termination
of a licensed senior operator, Docket No.20019, which occurred on September 8, 1989.This is a Severity Level IV violation (Supplement
I).MEM/HO-9002060/5/OS1
'I I'f
Denial or Admission and Reason for the Violation.
The violation is correct as stated.The violation occurred due to a lack of procedural
guidance which emphasized
the responsibilities
of licensed personnel/supervision
regarding 10CFR50.74.notification
requirements.
Corrective
Ste s Taken and Results Achieved: On October 16, 1990, a letter (H0-900151(0))
was transmitted
to NRC Region II formally requesting
that the subject license be terminated.
A complete review of Reactor and Senior Reactor Operator licenses was conducted.
This review identified
five other licensed operators for which no documentation
of termination
notification
to the NRC could be found.On December 17, 1990, a letter (HO-900203(0))
was transmitted
to NRC Region II formally requesting
that these additional
licenses be terminated.
Corrective
Ste s Taken to Avoid Further Violations'.
Procedural
guidance will be developed which will emphasize the Harris Project's responsibilities
regarding 10CFR50.74.
Date When Full Com liance Will Be Achieved: Full compliance
is expected to be obtained by January 31, 1991, upon the development
of procedural
guidance as stated above.MEM/HO"9002060/6/OSl