ML18010A415
| ML18010A415 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/16/1991 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18010A414 | List: |
| References | |
| NUDOCS 9110080113 | |
| Download: ML18010A415 (7) | |
Text
ENCLOSURE 3
CsroHns Power 5 Light Company P.O. Sex t66 ~ Hew Hlil,N.C, 27562 SEP 6
199t R. B. AIQHKY Vice Preeicenl Mertie Hvcleet Ptejecl Letter Number:
HO-910118 (0)
Mr. S.
D. Ebneter, Regional Administrator United States Nuclear Regulatory Commission 101 Marietta Street, NM
- Atlanta, GA 30323 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO+ 50-400/LICENSE NO. NPP-63
RESPONSE
TO NRC SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Dear Mr. Ebnetert Carolina Power and Light Company (CP&L) has
~eceived and reviewed the Systematic Assessment of Licensee Performance (SALP) report transmitted by the NRC on July 23, 1991'his report covered the performance of the Harris Nuclear Project from December 1, 1989, to June 1,
1991.
CP&L has also had the benefit of the comments that were presented in the NRC's review of the SALP Board results in a meeting on August 1, 1991e Based on this information, CP&L has one comment on the text of the SALP report which is provided in the attachment to this letter.
CP&L is very pleased that the NRC views the performance of the Harris Nuclear Project as being superior.
The results of this SALP inrerval reflect a
continuing improving trend on the part of the Harris Nuclear Project.
Me are committed to ensuring that this trend continues and have outlined for ourselves several areas for additional improvement.
These items were discussed with you during our meeting on June 12, 1991.
Yours very truly, MCM!kjc Attachment R,
B. Richey Vice President Harris Nuclear Project cct Ms.
B. L. Mozafari Mr. J.
E. Tedrow~
Document Control Desk MKM/H0-9101180/1/OS 1 9110080113 910919 pgFt ADOCK 05000400 G
t'DR
Enclosure 3
ATTACHMENT SECTION Go SAFETY ASSESSMENT/QUALITY VERIFICATION Page 18, Sizth Paragraph, Fifth Sentencei The noted passage which states that "The licensee has xeduced the number of available QC inspectors
- snd, therefore has relied upon the craft to perform a significant amount of first level assessment" needs clarification.
The numbex's of and need fox QC Inspection personnel at the Harxis Nucleax Project is continuously evaluated'he number of inspectoxs has x'emained constant at the current level since 1989.
First level assessment by craft personnel is aLso periodically evaluated.
Certain activities that were previously witnessed by Quality Contxol personnel during construction have been turned over to engineering, supervisory or craft personnel for verification where deemed appropriately MEM/HO"9101180/2/OS1
" ENCLOSURE 4 SALP BOARD DISPOSITION OF CPEEL COMMENTS The SALP BOARD reviewed the CPSL comment on the initial SALP Report for Shearon Harris Nuclear Plant.
They proposed the following disposition:
1.
Page 18 (IV.G.1) Safety Assessment/equality Verification Discussion:
The Board concludes the licensee's comment is correct.
The number of inspectors has remained constant and has not been reduced.
Changes:
An errata to pages 18 and 19 are Enclosure 5.
ENCLOSURE 5
ERRATA SHEET
~Pa e
Coversheet 18 19 Line 47 Initial SALP Re ort INITIAL SALP REPORT The licensee has reduced...
...and, therefore, has relied upon...
Final Re ort Reads FINAL SALP REPORT The licensee has maintained...
...in addition has relied upon...
U. S.
NUCLEAR REGU TORY COMMISSION RE ON II SYSTEMATIC ASS SMENT OF LICENSEE PERFORMANCE I
PECTION REPORT NUMBER 50-400/91-12 CAROLINA POWER
& LIGHT SHEARON HARRIS DECEMBER 1, 1989 - June 1,
1991
18 involving losses of offsite power.
Recommendations rom this team included completion of a
customer/supplier
- reement, closeout inspections following maintenance of ectrical equipment, expansion of thermography surveillan to include major electrical transmission components, and istribution of operating experience feedback information to he transmission department.
The licensee is in the proces of implementing these recommendations.
Selected plant nuclear safety committee eetings were observed.
Good participation and advance prepara on by committee members for those items discussed were noted.
Minutes from the meetings contained accurate documentation of e committee's activities.
Plant management continued to pe form weekly inspections of various plant areas.
The ins ection team consisted of approximately 10 managers, led y the plant general
- manager, and focused on the general clean iness and material condition of equipment.
This type of ma gement involvement had a positive effect on plant housekee ng and general managers were frequently seen in the p ant observing work in progress and performing plant tours.
Management decisions egarding plant safety were considered very conservative in mo cases.
Although not required by regulations, plant management made decisions to shut the unit down to repair a small secondary-side steam
- leak, and again, after detecting steam generator tube leak.
A non-conservative management de sion was
- made, however, following the 1989 refueling ou ge which allowed plant heatup without the main condenser ailable as discussed in the Plant Operations section.
In Janu y 1991, the licensee implemented a new non-conformance repor ng system which replaced Significant Operational Occu ence Reports with Adverse Condition Reports.
The new system established a lower threshold for reporting problems a
included other reporting systems to improve problem
- ending, root cause, and human performance analysis.
Good self-identification of problems was considered to be a major strength in the assessment area.
In January
- 1991, the licensee made organizational changes to provide three levels of self-assessment and created the Nuclear Assessment Department (NAD) from the Corporate Nuclear Safety and Onsite Nuclear Safety departments.'he first level of assessment consisted of individual self checks, supervision and monitoring of work performance, and management review of performance indicators.
The second level was a centralized review of plant performance in various functional areas by the Nuclear Service Department.
The third level of assessment was an independent review performed by NAD.
The licensee has reduced the number of available gC inspectors and, therefore,
19 has relied upon the craft to perform a significant ount of first level assessment.
Problems were identified ith plant personnel failing to perform adequate independent erifications at the Harris facility and at the licensee's o
er nuclear plants.
This indicated that the licensee has t achieved the desired results from the first level assessme t process.
The Nuclear Service Department created critical ccess factors for functional areas to aid in the assessment p riod; revisions to the critical success factors were being scussed with site personnel to improve this assessment.
Performance of 10 CFR 50.59 reviews c
tinued to be strong.
A new program was implemented to furt r strengthen this area.
The 10 CFR 50.59 evaluations refle ed.management involvement consistent with the safety signif cance of the issue.
Those issues with considerable comple ty and safety significance exhibited evaluations which in cated that decision making was consistently at a level that a sured adequate management review.
Evaluations in support of co lex license amendments such as the reactor level heatup and oldown
- curves, demonstrated an understanding of the tec ical issues involved and required little additional inform ion from the licensee.
The licensee devoted onsiderable resources to planning and scheduling licensing activity.
This planning exhibited a
considerable degre of management involvement and review.
Activities were p
nned to anticipate actions thereby avoiding the need for em gency amendments and waivers of compliance.
The licensee d
onstrated responsiveness in closing out TMI
- items, Generic Letters, and Bulletins.
One violati was cited.
2.
Performa e Ratin 3.
Categ y:
1 Rec endations e
Board noted the conservative approach to safety issues demonstrated by the licensee.
However, the effectiveness of the three levels of self-assessment has not been demonstrated.
Management review of the effectiveness of the organizational changes should be conducted.
ING DATA Licensee Activities The plant began the assessment period in the defueled condition during refueling outage 2.
Power operations resumed December 22, 1989.
The unit was shutdown on May 19, 1990, to perform repairs on a
leaking steam generator instrument isolation valve, the emergency