ML18010B132

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-400/93-03.Violation A,Example 1 Did Not Constitute Violation & Violation B Should Be Changed to non-cited Violation
ML18010B132
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 06/10/1993
From: Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Vaughn G
CAROLINA POWER & LIGHT CO.
References
NUDOCS 9307230071
Download: ML18010B132 (9)


See also: IR 05000400/1993003

Text

Docket No. 50-400

License

No. NPF-63

Carolina

Power

and Light Company

ATTN:

Mr. G.

E. Vaughn

Vice President

Shearon Harris Nuclear

Power Plant

P. 0.

Box 165

- Mail Zone

1

New Hill, NC

27562-0165

Gentlemen:

SUBJECT:

NRC

INSPECTION

REPORT

NO. 50-400/93-03

Thank you for your response

of March 26,

1993, to our Notice of Violation

issued

on February

25,

1993,

concerning activities conducted

at your Shearon

Harris facility.

We have evaluated

your response

and found that it meets

the

requirements

of 10 CFR 2.201.

After reviewing your letter,

we agree with your conclusion that Violation A,

Example

1, did not constitute

a violation.

We also agree that Violation B

should

be changed

from a Severity Level

V Violation to

a Non-Cited Violation.

Accordingly,

we will adjust our records to reflect that no cited violation of

regulatory requirements

occurred with respect to Violation A, Example

1 and

Violation B.

In your response,

you denied Violation A, Example 2.

You stated

as the bases

for your denial that

an alternate

means of transmitting plant operating data

to the Technical

Support Center

(TSC)

and

Emergency Operations Facility (EOF)

was available

and, that the problem that ultimately would cause

the non-

operational

state

noted

by the inspector

had

been recognized

on January

21,

1993.

After careful consideration of the bases for your denial of Violation A,

Example 2,

we have concluded, for the reasons

presented

in the enclosure to

this letter, that the violation occurred

as stated

in the Notice of Violation.

Therefore,

in accordance

with 10 CFR 2.201(a),

please

submit to this office

'ithin

30 days of the date of this letter

a written statement

describing

steps

which have

been taken to correct Violation A, Example 2,

and the results

achieved,

corrective steps

which will be taken to avoid further violations,

and the date

when full compliance will be achieved.

We will examine the implementation of your actions to correct the violations

during future inspections.

930723007i

930610

PDR

ADOCK 05000400~

8

PDR .

~go I

Carolina

Power

and Light Company

2

The responses

directed

by this letter

and its enclosure

are not subject to the

clearan

e procedures

of the Office of Management

and Budget

as required

by the

Paperwork Reduction Act of 1980,

Pub.

L.

No 96-511.

We appreciate

you cooperation

in this matter.

Sincerely,

Enclosure:

Evaluations

and Conclusions

J. Philip Stohr, Director

Division of Radiation Safety

and Safeguards

cc w/encl:

W.

R. Robinson

Plant Manager

Harris Nuclear Plant

P. 0.

Box 165

New Hill, NC

27562-0165

Mr. H.

W. Habermeyer,

Jr.

Vice President

Nuclear Services

Department

Carolina

Power

8 Light Company

P. 0.

Box 1551

- Mail OHS7

Raleigh,

NC

27602

C,

S. Olexik, Jr.,

Manager

Regulatory Compliance

Harris Nuclear Project

P. 0.

Box 165

New Hill, NC

27562

H.

Ray Starling

Vice President

- Legal

Department

Carolina

Power

and Light Co.

P. 0.

Box 1551

Raleigh,

NC

27602

Dayne

H. Brown, Director

Division of Radiation Protection

N. C. Department of Environment,

Health

5 Natural

Resources

P. 0.

Box 27687

Raleigh,

NC

27611-7687

cc w/encl:

(Cont'd

on page

3)

Carolina

Power

and Light Company

(cc w/encl:

cont'd)

Hs. Gayle

B. Nichols

Staff Counsel

SC Public Service

Commission

P. 0.

Box 11649

Columbia,

SC

29211

bcc w/encl:

H. Christensen,

RII

S. Vias, RII

N. Le,

NRR

Document Control

Desk

NRC Resident

Inspector

U.S. Nuclear Regulatory

Commission

Route

1,

Box 315B

New Hill, NC

27562

RI

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ENCLOSURE

EVALUATION AND CONCLUSION

On February

25,

1993,

a Notice of Violation (Notice)

was issued for violations

identified during

a routine

NRC inspection.

Shearon

Harris responded

to the

Notice on March 26,

1993.

In the licensee's

response

to the Notice, -the

Violation was denied

because

there were alternate

means of transmitting plant

data

and because

the ultimate source of the problem which made the

Emergency

Response

Facility Information System

(ERFIS) terminal fail to operate

had

been

recognized

several

days before the

ERFIS terminals

were found by the

NRC to be

inoperable.

Restatement

of Violation A

Exam le

2

10 CFR 50.54(q)

states

that

a licensee

authorized to possess

and operate

a

nuclear

power reactor shall follow and maintain in effect

an emergency

plan

which meets

the standards

in 10 CFR 50.47(b)

and the requirements

of

Appendix

E to

10 CFR Part 50.

10 CFR 50.47(b)(8) requires that adequate

emergency facilities and equipment to support the emergency

response

are

provided

and maintained.

Section 3. 1 of the Shearon

Harris Emergency

Plan,

which implements

10 CFR 50.47(b)(8),

states

that adequate

emergency facilities, communication,

and equipment to support

emergency

response

are provided

and maintained.

Section 3.5.3.b of the Shearon

Harris Emergency

Plan identifies

ERFIS

consoles,

capable of displaying plant data,

Safety

Parameter

Display System

(SPDS),

and Radiation Monitoring System

(RMS),

as

Emergency Operations

Facility (EOF) equipment to be maintained.

Contrary to the above,

when

an operational

demonstration

was requested

by the

inspector,

EOF ERFIS terminals

1, 2,

and

3 did not operate.

Summar

of Licensee's

Res onse:

The licensee

stated "It is true that when

an operational

demonstration

was

requested

by the inspector

on January

26,

1993, the

EOF ERFIS terminals

1, 2,

and

3 did not operate."

The licensee

also

argued that alternate

means of

transmitting plant operating data to the Technical

Support .Center

(TSC)

and

EOF was available.

In addition, the licensee

stated that the problem that

ultimately would cause

the non-operational

state

noted

by the inspector

had

been recognized

on January

21,

1993,

and that

a work ticket was initiated at

that time.

The licensee

stated

the

EOF equipment

had

been operating properly

just prior to the

NRC inspection

but that

a component failed to operate

.

properly when actuated

as part of the upgrade to the

ERFIS.

The licensee

stated

the

EOF equipment

was placed

back on line within 30 minutes the day

after the equipment

was identified by the

NRC as being out of service.

The

licensee

contends

the issue is not

a violation in that the problem

had

been

self-identified

and the ability to place the equipment

back on line was

available

and demonstrated.

Encl.osure

NRC Evaluation

The licensee

agreed that the

ERFIS terminals failed to operate

when requested

by NRC.

The

NRC inspector

was

aware that

an alternate

means of transmitting

plant operating data to the

EOF was available

and concluded that such measures

should

be taken to compensate

for the loss of the

ERFIS terminals.

However,

the violation was concerned with the maintenance

of the

ERFIS terminals.

Compensatory

measures

are not

a substitute for adequate

maintenance

of

required equipment.

The

ERFIS system

has

a history of problems.

During a previous inspection in

June

1991,

a similar problem occurred with the

ERFIS.

Specifically, all of

the

EOF ERFIS terminals failed to function on

command

and required technical

assistance

to activate.

At that time,

a work request

had

been

issued to

attempt to identify the problems.

That failure of the terminal to operate

was

subsequently

classified

by

NRC as

a non-cited violation based

on licensee

planned corrective action to upgrade

the system.

During this inspection,

the

ERFIS terminals

again failed to operate

when requested

and the immediate

attempt to trouble shoot the system

was unsuccessful.

To examine the

maintenance

history of the

ERFIS system,

the inspector

requested

a current

listing of work requests

on the

ERFIS system.

That listing indicated that

a

substantial

number of work requests

were awaiting completion.

The work

request list indicated that

ERFIS needed

increased

attention to assure

the

system

was maintained

in an operable state consistent

with its emergency

response

function.

Also,

on February

6,

1993, following the subject

NRC

inspection,

the licensee

met

an established

emergency

action level

and

declared

a Notification of Unusual

Event when the

ERFIS computer failed to be

operable for more than four hours.

The licensee

stated that they maintain technical

personnel

capable of working

on the

ERFIS system

and they have the ability to rapidly return the system to

operational

status.

The

NRC noted that

a technician initially wrote

a work

ticket on the January

21,

1993,

which identified the failed "switcher."

The

work ticket did not prevent another technician

from activating the "switcher"

on the morning of January

26,

1993, which,

as stated

by the licensee,

was the

source of the

EOF

ERFIS terminal failure.

The Specialist

contacted

on the

evening of January

26,

1993,

was unable to activate the

EOF ERFIS terminals.

Neither the Specialist

nor the technician contacted

by the Specialist

were

aware of the defective

equipment.

The equipment

was not returned to service

until the following day after

a review by the technician

who normally works

on

the equipment.

The activation of the "switcher" by a technician resulted

in

the

EOF ERFIS terminals

being inoperable for a period of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

NRC Conclusion

The inspector

concluded that the long standing

problems with the

ERFIS system

had not been

adequately

resolved in the intervening years

between

June

1991

and January

1993.

After careful

review and consideration

of the licensee's

basis for the denial

of Violation A, Example 2, the

NRC has concluded

the violation as stated

is

valid.

l: