ML12312A126

Reply to Notice of Violation; EA-12-132, NRC Inspection Report 05000400-12-010

ML12312A126
Person / Time
Site:	Harris
Issue date:	11/01/2012
From:	Hamrick G Duke Energy Corp
To:	Document Control Desk, NRC/RGN-II
References
EA-12-132, HNP-12-105, IR-12-010
Download: ML12312A126 (4)

See also: IR 05000400/2012010

Text

kDuke W EnergyGeorge T. Hamrick Vice President Harris Nuclear Plant 5413 Shearon Harris Rd New Hill NC 27562-9300

919-362-2502

November 1, 2012 Serial: HNP-12-105

ATTN: Document Control Desk U.S. Nuclear Regulatory

Commission

Washington, DC 20555-0001

Shearon Harris Nuclear Power Plant, Unit I Docket No. 50-400 Subject: Reply to Notice of Violation;

EA-12-132 NRC Inspection

Report 05000400/2012010

Ladies and Gentlemen:

Enclosed is Carolina Power & Light Company's

reply to the Notice of Violation

contained

in the enclosure

to your letter (EA-12-132)

dated October 3, 2012.This submittal

contains no new regulatory

commitments.

Please refer any questions

regarding

this submittal

to David H. Corlett, Supervisor

-Licensing/Regulatory

Programs, at (919) 362-3137.Sincerely, 1dO .-v--GTH/mgw Enclosure:

Reply to Notice of Violation;

EA- 12-132 cc: Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Ms. A. T. Billoch Col6n, NRC Project Manager, HNP Mr. V. M. McCree, NRC Regional Administrator, Region II arc)

Document Control Desk Enclosure

to HNP-12-105

Page 1 of 3 REPLY TO NOTICE OF VIOLATION;

EA-12-132 NRC INSPECTION

REPORT 05000400/2012010

Reported Violation

A: 10 CFR 50.54(q) requires, in part, that a licensee authorized

to operate a nuclear power reactor shall follow and maintain in effect emergency

plans which meet the standards

of 10 CFR 50.47(b).10 CFR 50.47(b)(8)

requires that adequate emergency

facilities

and equipment

to support the emergency

response are provided and maintained.

10 CFR 50, Appendix E, Section IV.E.8 (2011 version) states, in part, that the emergency facilities

shall include licensee onsite technical

support center and an emergency

operations

facility from which effective

direction

can be given and effective

control can be exercised

during an emergency.

The Harris Nuclear Plant Emergency

Plan, Section 3.1, revision 57, states in part that adequate emergency

facilities, communications, and equipment

to support emergency

response are provided and maintained.

Contrary to the above, on several occasions

between August 4, 2009, and November 9, 2011, the licensee failed to maintain adequate emergency

facilities

and equipment

to support emergency response.

Specifically, the Emergency

Operations

Facility (EOF) normal and emergency ventilation

system was in a degraded state and/or removed from service, for extended periods of time.This violation

is associated

with a White SDP finding.Reason for the Violation:

The reason for the violation

is that Harris Nuclear Plant (HNP) processes

and procedures

to ensure the functionality

and reportability

requirements

for the Emergency

Response Facilities

did not meet the standards

established

for the rest of the plant.Corrective

Steps Taken and Results Achieved: 1. Revised procedure

WCP-NGGC-0300, Work Request Initiation, Screening, Prioritization

and Classification

on September

10, 2012, to ensure that equipment

that is important

to facility readiness

is assigned a priority that considers

its importance.

The result of this action is that EOF equipment

repairs are now integrated

into the site's work management

system.2. Issued procedure

PLP-717, Equipment

Important

to Emergency

Preparedness

and ERO Response on October 11, 2012, to ensure that when equipment

important

to Emergency Preparedness (EP) is out of service for maintenance (planned or unplanned), or is in a

Document Control Desk Enclosure

to HNP- 12-105 Page 2 of 3 degraded condition, the correct restoration

priority is assigned;

compensatory

measures are implemented;

and the equipment

is promptly restored to a functional

operating

condition.

Corrective

Steps That Will Be Taken: To preclude further noncompliance, an action is underway to document the technical requirements

and administrative

controls needed for the EOF and Technical

Support Center to ensure performance

of design and licensing

basis functions.

This will include design review and documentation, procedures, and line ownership.

This action is currently

scheduled

to be completed

in December 2012.Date When Full Compliance

Will Be Achieved: Full compliance

was achieved November 9, 2011, upon completion

of testing following

repairs on EOF emergency

ventilation

isolation

damper D-3. The additional

actions stated above will further enhance our ability to maintain compliance.

Reported Violation

B: 10 CFR 50.72(b)(3)(xiii)

states that a licensee shall notify the NRC as soon as practical

and in all cases within eight hours of the occurrence

of any event that results in a major loss of emergency assessment

capability, offsite response capability, or offsite communications

capability (e.g., significant

portion of control room indication, Emergency

Notification

System, or offsite notification

system).Contrary to the above, on several occasions

between August 4, 2009, and November 9, 2011, the licensee failed to notify the NRC within eight hours of the occurrence

of a major loss of emergency

assessment

capability.

Specifically, the licensee failed to report that the EOF normal and emergency

ventilation

system was in a degraded state, and/or removed from service, for extended periods of time when portions of the ventilation

system were undergoing

repairs, testing and maintenance, without compensatory

measures.This is a Severity Level III violation (Enforcement

Policy paragraph

6.6).Reason for the Violation:

The reason for the violation

is that HNP processes

and procedures

to ensure the functionality

and reportability

requirements

for the Emergency

Response Facilities

did not meet the standards established

for the rest of the plant.Corrective

Steps Taken and Results Achieved: 1. Revised procedure

AP-617, Reportability

Determination

and Notification

on February 27, 2012, to specifically

incorporate

the reportability

requirements

of NUREG 1022 related to Emergency

Response Facilities.

As a result, HNP's reportability

threshold

is aligned with NRC requirements.

-0 .W Document Control Desk Enclosure

to HNP-12-105

Page 3 of 3 2. Issued procedure

PLP-717, Equipment

Important

to Emergency

Preparedness

and ERO Response on October 11, 2012, to provide guidance to the shift manager to ensure that when equipment

important

to EP is out of service or degraded, the condition

is evaluated for reportability

in accordance

with procedure

AP-617. The results of this action are a procedurally

driven connection

between equipment

important

to EP and reportability

guidance.Corrective

Steps That Will Be Taken: To preclude further noncompliance, an action is underway to document the technical requirements

and administrative

controls needed for the EOF and Technical

Support Center to ensure performance

of design and licensing

basis functions.

This will include design review and documentation, procedures, and line ownership.

This action is currently

scheduled

to be completed

in December 2012.Date When Full Compliance

Will Be Achieved: Full compliance

was achieved on October 30, 2012, when HNP submitted

to the NRC Operations

Center a supplement

to event notification

report EN-47775 for past periods where the EOF was in a non-functional

status. The additional

actions stated above will further enhance our ability to maintain compliance.