ML18005A711
| ML18005A711 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/23/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-651 HO-880236-(O), NUDOCS 8811300410 | |
| Download: ML18005A711 (8) | |
Text
<<LgMTED DISXRIBUTJON DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR: 8811300410 DOC. DATE: 88/11/23. NOTARIZED: NO DOCKET g FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION WATSON,R.A. Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 881025 ltr .re deviations noted in Insp Rept 50-400/88-29'ISTRIBUTION TITLE: General CODE:
(50 IE01D COPIES RECEIVED:LTR ENCL Dkt)-Insp Rept/Notice of Vi lation Response 4 SIZE:
NOTES:Application for permit renewal filed. o5ooo4oo >
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD 1 1 BUCKLEY,B 1 1
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INTERNAL: ACRS 2 2 AEOD 1 1 DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR/DLPQ/PEB 11 NRR/DOEA DIR NRR/DREP/RPB 10 ll 1 1
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1 NRR/PMAS/ILRB12 1. 1 NUDOCS-ABSTRACT 1 1 OE LIEBERMAN,J 1 1 OGC/HDS1 1 1 FI 02 1 1. RGN2 FILE 01 1 1 ERNAL: LPDR 1' NRC PDR 1 1 NSIC 1 1 RESL MARTIN,D 1 1 A,.
NOZE XO ALL RIDS" RECZPIEÃIS: D PIERCE HELP US TO REDUCE %ASTEl CXRKACZ THE DOQ2KNT CONTROL DESK RQGN Pl-37 (EZZ. 20079) TO ELIMINATE YOUR MHE FRY DISXEG:BUTIGN IZSTS H)R DOCX2KNTS YOU DCtNIT NEED~
TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL . 24
NOV 25 1988 HARRIS NUCLEAR PROJECT P. 0. Box 165 New Hill, North Carolina 27562 File Number'. SHF/10-13510E Number. HO-880236 (0) 'etter NRC-651 Document Control Desk 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 DEVIATION, Gentlemen:
In reference to your letter of October 25, 1988, referring to I.E.
Report RII: 50-400/88-29, the attached is Carolina 'Power & Light Company's reply to the deviation identified in the enclosure.
It is considered that the actions taken are satisfactory for resolution of this matter.
Thank you for you consideration in this matter.
Very truly 'yours, R. A. Watson Vice President Harris Nuclear Project MGW:crc Attachment cc: 'Messrs. W. H. Bradford (NRC-SHNPP)
B. C. Buckley (NRC)
M. L. Ernst (NRC) g~ll~O(y41O 8+112$
OgOOO400 PDR AOOCi<
Q PDC MEM/HO-8802360/1/OS1
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Re orted Deviation:
Shearon Harris Nuclear Power Plant (SHNPP) FSAR, Section 1.8 Conformance to NRC Regulatory Guides states.'...SHNPP complies with IEEE Standard 338-1977, Reg. Guide 1.118."
IEEE Standard 338-1977 requires, in part, that a test program be implemented that produces objective data for evaluating (assessing) the performance and availability of the component being tested, and that the data be trended to allow for the detection of degradation and indication of incipient failures.
Contrary to the above, on September 1, 1988, 27 of SO Maintenance Surveillance Tests that were reviewed contained as found data that was outside of its allowable range. The licensee did not have a program to evaluate the out-of-range readings, nor was there a program to trend instrument drift as required by the above.
Reason for the Deviation:
CPhL agrees that a formal program to comply with the evaluation and trending requirements for'instrumentation calibration was not in place at the time of the inspection. However, CP&L disagrees that the 27 items noted required evaluation under such a program.
This is best explained by the definitions used in instrument.
calibrations. The following definitions are provided to clarify this '.
- l. Allowable Range'The tolerance used in calibration procedures (less than or equal to the allowable limit).
- 2. Allowable Limit: The tolerance specified in the design set point document.
- 3. Allowable Value: The Tech. Spec. value which a set point must trip before to remain within Westinghouse set point margin allowances.
- 4. Tech. Spec. Limit: Total allowance as defined in Tech.
Spec.
Twenty-seven out of fifty Maintenance Surveillance test calibration procedures, "as found" values, were found outside. of the "allowable range" but not outside the "allowable value". The Westinghouse set point study addresses instrument drift and this basis is incorporated in the set point document. From the set point listed in the Technical Specification the "allowable value" has been established. In the majority of the cases, SHNPP intentionally made tolerance bands or "allowable range" more conservative than the "allowable limit" which reduces the possibility of exceeding the -"allowable limits" or Technical Specification "allowable value." Due to this fact, we .do not trend those devices that are outside of the "allowable range."
MEM/HO-8802360/2/OS1
Not withstanding the lack of a formal program, when instruments were found outside of the "allowable value," in particular, two separate episodes of Pressurizer Pressure Transmitter drift, the situation was evaluated.
Corrective Ste s Taken and Results Achieved:
Since the twenty-seven as found values identified were outside of the "allowable range" but not outside of the "allowable value" trending was not performed.
Corrective Ste s Taken to Avoid Further Deviations'.
The existing program will be modified to "evaluate" and "trend" those devices found out of the "allowable value" criteria. These program changes are projected to be completed by March 1, 1989.
'In the interim, instructions will be issued to appropriate
'maintenance personnel requiring that when readings exceed the "allowable value," maintenance engineering is to be notified to, perform an evaluation. This action will be completed by December 2, 1988.
Date When Corrective Action will be Com leted:
Corrective action is projected to be complete, by March 1, 1989.
MEM/HO"8802360/3/OS1
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