ML18022B021

Ack That Corrective Actions as Implemented W/Regard to Item Deviates from Ones Which Were Described in NOV Response Dtd 960408 & Stated in LER 96-001-00

ML18022B021
Person / Time
Site:	Harris
Issue date:	08/11/1997
From:	Robinson W CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-400-96-01, 50-400-96-1, HNP-97-157, NUDOCS 9708150058
Download: ML18022B021 (3)

Text

REGULATO INFORMATION DISTRIBUTION TEM (RIDS)

ACCESSION NBR:9708150058 DOC.DATE: 97/08/11 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION ROBINSON,W.R. -

Carolina Power a Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Ack that corrective actions implemented w/regard to blocking open of RABEES boundary w/o prior control room approval, knowledge or control deviate from those described in 960408 reply a stated in LER 96-001-00.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-,Insp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 PD ROONEYiV

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R INTERNAL: ACRS 'AEOD/SPD/RAB DEDRO Y r NRR/DISP/PIPB NRR/DRPM/PECB NRR/DRPM/PERB NUDOCS-ABSTRACT OE DIR OGC/HDS2 RGN2 FILE 01

'XTERNAL LITCO BRYCEg J H NOAC D NRC PDR NUDOCS FULLTEXT 0

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL

Carolina Power & light Company William R. Robinson Po Box 1 65 Vice President New Hill NC 27562 Harris Nuclear Plant AUG 1 1 19S7 SERIAL: HNP-97-1 57 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HAIUUS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 SUPPLEMENT NO. 2 TO A REPLY TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-400/96-01)

Dear Sir or Madam:

On April 8, 1996, Carolina Power & Light Company responded to a Notice of Violation (NOV) enclosed in NRC Inspection. Report 50-400/96-0 1 'ated March 8,' 996 for the Harris Nuclear Plant. The violation,was regarding the . blocking open of a Reactor Auxiliary Building Emergency Exhaust System,(RABEES) boundary door. without prior control room approval, knowledge or control, rendering both trains of RABEES inoperable. This event was also reported in LER 96-00 1 -00 dated February 9, 1 996.

The April 8, 1 996 reply, under Corrective Ste s Taken to Avoid Further Violations stated:

"A plant modification will be installed that provides alarming capability for RAB Emergency Exhaust System boundary doors. This modification will be completed by September 30, 1996."

On July 24, 1 997, based on further review, HNP submitted a supplemental- reply to the NRC which provided clarification of.the corrective action as implemented. This supplemental reply stated that the action plan for addressing alarming capability for RABEES boundary doors had included determining if and which RABEES boundary doors could be locked and administratively controlled and determining if any of the doors could be reclassified as non-boundary doors. As a result of engineering evaluation and modification, of the previous O twenty-five RABEES boundary doors, seven doors were alarmed, ten doors were locked M+5 requiring Operations approval of a breach request prior to blocking open, and eight stairwell Oa.

QO doors were reclassified as non-boundary doors, by extending the RABESS boundary to envelop 39 OO the doors, These corrective actions'were,completed. by September 30,.1996.

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'NP CI eSe acknowledges that the coirective actions as implemented with regard to this item'eviate LAO O Cl &om th'ose which " were described in our NOV reply dated April O Cl 8, 1 996 and stated in AC LER 96-00 1 -00. This deviation resulted from a failure to clearly communicate in the LER and rrt NOV reply the planned corrective actions. During the period prior to September 30, 1 996, Oae t rect personnel were aware of the actual corrective actions a a.e being implemented but failed to recognize Stele Rmd 1134 N~ Hlll Nc Tel 919 362-2502 F~ 919362-2095

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iV I Document Control Desk j SERIAL: HNP-97-157 r

the need to supplement the LER and NOV reply dated April 8, 1996. As discussed in this letter, the April 8, 1996 NOV. reply has been supplemented to fully describe the corrective actions taken. These corrective actions also apply to the LER.

Restricting access by locking selected doors closed in lieu of providing alarms is an appropriate control for maintaining an adequate RABEES boundary. Those doors locked and requiring a key for entry represent the only access to the applicable areas unless alternate access exists through an alarmed door. Ifalternate access exists through an alarmed door the locked door is pad locked thereby preventing exit through the locked door without a key with one exception as noted below. It has been recently identified that in one case (Door 615 - Reactor Auxiliary Building 236'echanical penetration area), the door is locked &om outside access only and permits exit without a key for personnel safety reasons. Entry to the same area is available through other alarmed doors. Therefore, exit through this door is neither monitored by alarm nor restricted by locking. An alarm function willbe added to this door by October 31, 1997.

Since the original corrective actions were implemented on September 30, 1996, there have been no condition reports generated due to RABEES boundary doors being blocked open without proper approval. Questions regarding this matter may be referred to Mr. J. H. Eads at (919) 362-2646.

Sincerely, MGW/mgw c: Mr. J. B. Brady (NRC Senior Resident Inspector, HNP)

Mr. L. A. Reyes (NRC Regional Administrator, Region II)

Mr. V. L. Rooney (NRR Project Manager, HNP)