ML20213G218
| ML20213G218 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/03/1986 |
| From: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NLS-86-412, NUDOCS 8611170388 | |
| Download: ML20213G218 (4) | |
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[, I P. O. Box 1551
- Raleigh, N. C. 27602 3 M SERIAL: NLS-86-412 M. A. McDUFFIE Senior Vice President Nuclear Genershon Dr. 3. Nelsen Grace, Regional Administrator United States Nuclear Regulatory Commission 101 Marietta Street, NW Atlanta, GA 30303 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/ LICENSE NO. NPF-53 RESPONSE TO NRC SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT NO. 50-400/86-56
Dear Dr. Grace:
Carolina Power & Light Company (CP&L) has reviewed the Systematic Assessment of Licensee Performance (SALP) Board Report forwarded by your letter dated September 25,1996, which evaluated CP&L's performance at the Shearon Harris Nuclear Power Plant during the period from November 1,1985 through July 31,1986. We are pleased with the Board's recognition of CP&L's performance and continued demonstration of proper concern for nuclear safety. We also appreciate your (and your staff's) comments at our meeting of September 30,1986, which further explained the SALP Board's evaluation of CP&L's safety performance.
Carolina Power & Light Company is concerned, however, that the SALP Board has not given full value to all of CP&L's achievements in improving safety performance during the period of evaluation. Specifically, we believe that the Instrumentation and Training and Qualification Effectiveness areas should be rated higher; the basis for our belief is provided in the attachments.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Yours very truly, gQ h ' ^77 _e -
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M. A. McDuffie GAS /bmc (5046 GAS)
Attachments cc:
Mr. B. C. Buckley (NRC)
Mr. H. R. Denton Mr. G. F. Maxwell (NRC-SHNPP) hbk 00$
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SHEARON HARRIS NUCLEAR POWER PLANT SALP REPORT NO. 50-400/86-56 Instrumentation (SALP Board Rating: Category 2)
Carolina Power & Light Company believes that a Category I rating is warranted in this area.
Continued strong management attention was evident during this assessment period. Significant changes were made in the engineering support area to shift design responsibility from Ebasco (the Architect / Engineer) to the onsite Harris Plant Engineering Staff (HPES). Stress analysis calculation responsibility was transferred from Ebasco to HPES to provide onsite resolution of field questions. Site engineering was staffed and had developed the cap 6111ty to perform onsite original design of instrument supports and restraints. HPES and Harris Plant Construction Staff (HPCS) personnel were placed in the field to provide direct assistance to craft personnel and craft supervision, thereby providing timely resolution of field installation questions.
An engineering review of applicable work and inspection procedures strengthened and provided more consistent criteria in this area. Work packages were assembled and reviewed for completeness prior to issuance to the field. Assembled packages were streamlined for clarity and conciseness which ensured the final acceptance.
Quality Assurance / Quality Control personnel were well qualified for their job functions and knowledgeable of procedural requirements. Quality Assurance audits / surveillance activities of this area identified excellent results. Attribute ratings increased from 91.7 percent (9/85) to 99.9 percent (11/85-6/86) for both construction and inspector performance. Staffing in this area was adequate for the level of construction activity.
Records were complete, well maintained, and retrievable.
In summary, CP&L initiated the above changes to allow for the timely completion of the instrumentation work. CP&L management attention and involvement are aggressive and oriented toward nuclear safety, and CP&L resources are adequate and effectively used so that a high level of performance is being achieved. Therefore, a Category I rating is justified.
(5046CAs/bmc )
e SHEARON HARRIS NUCLEAR POWER PLANT SALP REPORT NO. 50-400/86-56 Training and Qualification Effectiveness (SALP Board Rating: Category 2)
Carolina Power & Light Company (CP&L) believes that a SALP category of 1 is justified for the Shearon Harris Nuclear Power Plant. A strong comprehensive training and qualification program has been implemented at the Harris Plant. This program is similar in depth and scope to the training programs at the Robinson and Brunswick plants which have successfully supported operation of these plants for many years. The Harris Plant Training program is based on a systematic approach to training, is in accordance with NRC regulations, and is consistent with INPO training guidelines.
The Harris Training staff consists of 25 permanently assigned personnel supported by 17 qualified contractors. A long-term permanent staff for the Harris Training Unit is expected to be about 40. The Harris Training Unit is supported by five other training units located at the Shearon Harris Energy & Environmental Center (SHE&EC) which provide generic training for craf t and technical personnel and simulator training for Harris operators. The training staff at the SHE&EC consists of about 65 personnel.
The original Shearon Harris simulator was delivered and placed into operation in 1978. It was used to train Harris operators and management personnel until August 1985 when it was removed and replaced by a more modern site-specific simulator. Training of Harris candidates began on this simulator in February 1986.
Carolina Power & Light Company has been an industry leader in attaining INPO accreditation of its training program. In September 1986, CP&L became the fourth member overall and the first multi-site member of the National Academy for Nuclear Training. Academy membership was achieved when all ten eligible training programs were granted accreditation at both Robinson and Brunswick plants. In addition, the Harris Plant has been a Branch of the National Academy for Nuclear Training since December 1985 and currently has six of its ten eligible training programs accredited.
These are the most accredited programs at any NTOL plant in the U.S. In addition, the Self-Evaluation Reports for the remaining four training programs at Harris (non-licensed operator, reactor operator, senior reactor / shift supervisor, and STA) were submitted to INPO in September 1986. Since the INPO deadline for having training programs at NTOL plants ready for accreditation is two years af ter fuel load, the Harris Plant is over two years ahead of schedule on accreditation activities.
Another significant aspect of CP&L's training programs is its implementation of the Craf t & Technical Development (C&TD) Program, an integral part of the overall plant training qualification program.
The C&TD Program integrates training with the employee promotion process.
A prerequisite for participants to be promoted is to successfully attend and pass annual training provided at the SHE&EC. Classifications participating in this program are mechanic, electrician,1&C technician, radiation control technician, environment & chemistry technician, and radwaste operator.
I Cold license training for operators has generally been successful. Of the 70 Group 1 and Group 2 candidates taking the NRC written exam,69 passed, a success rate of 99% For the written and oral exams combined, the pass rate was 97% In May 1986, 24 of 34 candidates passed the NRC simulator exam for a success rate of 71% (one candidate's appeal was ruled in his favor). Although this pass rate was not as high as anticipated, the (5046 gas /bmc )
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proficiency of Harris operators is expected to increase throughout 1986 as they receive additional training on the simulator. Group I candidates have or will receive at least five additional weeks of training on the new simulator. Of the first sixteen Group 2 l
candidates who took the NRC simulator exam in September 1986,12 passed for a success rate of 75%
A comprehensive plant-specific training program is in place at the Harris Plant. This training is governed by the Nuclear Training Section Training Manual, a document approved by the Senior Executive Vice President of Power Supply, Engineering, &
Construction.
In the area of maintenance training (mechanic, I&C technician, and electrician), Harris Plant specific training is governed by Training Instruction 113. This document was approved and in place prior to the SALP reporting period.
Harris Training has had a minimum of adverse findings from INPO, QA, and NRC. During the SALP reporting period, there were no NRC violations identified.
(5046 GAS /bmc )
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