ML18005A715

Responds to NRC Re Violations Noted in Insp Rept 50-400/88-33.Corrective Actions:Fire Watch Personnel Cautioned on Seriousness of Not Complying W/Hourly Fire Watch Requirements

ML18005A715
Person / Time
Site:	Harris
Issue date:	11/29/1988
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-652 HO-880237-(O), NUDOCS 8812050191
Download: ML18005A715 (9)

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AC'CELERATED 111 SIBUTI ON DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8812050191 DOC.DATE: 88/11/29 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1 Carolina AUTH.NAME AUTHOR AFFILIATION WATSON,R.A.

Carolina. Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION'ocumentControl Branch (Document Control Desk)'0

~88-33.

SUBJECT.:

Responds to NRC 881031 ltr re violations noted R t in nsp ep DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL i SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response

~ NOTES:Application for.permit renewal filed.1 I

DOCKET I 05000400 D

S 05000400 INTERNAL:

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XTERNAL RECIPIENT ID CODE/NAME PD2-1 PD ACRS DEDRO NRR/DLPQ/PEB.11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE LI (J

IL 02 LPDR NSIC 4

COPIES LTTR ENCL 1

2 2

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1 1'ECIPIENT ID CODE/NAME BUCKLEY,B AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRAC'g GGC/HDS 1 RGN2 FILE 01'RC PDR RESL MARTIN,D COPIES LTTR ENCL 1

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'10 ALL "RIDS" RECZPIENIS HASTE.

CORI'ACI'lHE DOCUMEP1'ONIHOL DESK,

-37 (EXT. 20079)

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%OR DOCUMEMXS-~ DGNIT NEZDL TOTAL NUMBER OF COPIES REQUIRED:

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Carolina Power

~~ t toi.t Con:qany BIO'I/ 2 9 is";.

HARRIS NUCLEAR PROJECT P.

O.

Box 165 New Hill, North Carolina 27562 File Number'SHF/10-13510E Letter Number:

HO-880237 (0)

NRC-652 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 4

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SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO ~ NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

.In reference, to your letter of October 31 1988 ref Report RII:

50-400/

, re erring to I.E..

/88-33, the attached is Carolina Power 6 Light Company',s reply to the violation identified in Enclosure 1.

It is considered that the corrective actions taken/planned are satisfactory for resolution. of the item.

Thank you for you consideration in this matter.

4 Very truly yours, C.H R. A. Watson Vice President Harris Nuclear Project MGW:tbb Attachment cc:

Messrs.

W. H. Bt.'adford (NRC-SHNPP)

B. C. Buckley (NRC)

M. L. Ernst (NRC)

SS12050191 SS1129 PDR ADOCK 05000400 Q

PDC MEM/HO"8802370/1/OS1

Attachment to CP&L Letter of Res onse to NRC I.E.

Re ort RII:

50-400 88-33 Violation Re orted Violation:

Technical Specification 6.8.1.h requires that applicable written procedures be established, implemented, and maintained for the fire protection program.

1.

Plant Fire Protection Program Procedure FPP-013,'Fire Protection Minimum Requirements and Mitigating Actions,"

requires the licensee to establish hourly, fire watch patrols in areas where equipment is required to be operable w'hen fire barriers are degraded.

0 Contrary to the

above, between September 2,

1988, and September 10,

1988, there were eight recorded occurrences where hourly fire watch patrols were not performed in the "B" diesel generator building when the "B" diesel generator was required to be operable and fire barriers were degraded.

2.

Operations Management Manual Brocedure OMM-033, "Equipment Inoperable

'Record,"

requires the licensee to complete an

~ equipment inoperable record form and to immediately deliver

~ it to the shift foreman for his evaluation of equipment operability when a

fire protection component becomes inoperable.

k Contrary to the above, on September 9, 1988, a three hour and a one hour fire barrier in the "B" diesel generator building were found to be breached and

were, therefore, inoperable',

but an equipment inoperable record had not been completed as required.

This, is a Severity Level IV violation (Supplement I).

Denial or Admission and Reason for the Violation'.

The violation is correct as stated.

Fire watch personnel were aware of their responsibilities, but failed to recognize the seriousness and consequences of noncompliance.

The problem with fire watch personnel making improper inspections was previously identified by the licensee and aggressive action to correct the problem is being pursued.

MEM/HO-8802370/2/OS1

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The fire barriers noted by the inspector were breached as

.stated but the specific reason for the discrepancy was not apparent.

Work had been performed recently for which cables were routed through the barrier penetrations, but since the penetrations were already open prior to the work, personnel did not realize that it was a fire barrier which was required to be sealed and therefore the discrepancy was not identified and corrected.

Corrective Ste s Taken and Results Achieved:

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Fire watch personnel were cautioned on the seriousness of not comp).ying with hourly fire watch, requirements.,

Disciplinary ac'tion has been taken against the individuals involved which included five terminations.

k r

As soon as the potential violation was brought to the

.attention of Operations, an Equipment Inoperable Record (EIR) was initiated and a fire watch assigned in accordance with plant procedures.

In addition, a site Nonconformance Report (NCR-88"083) was initiated.

C Corrective Ste s Taken to Avoid Further Violations:

An electronic key system has been installed and 'patrol area

'maps prove.ded to fire watch.personnel.

The electronic key system provides a method of verifying that areas requiring a

fire watch are visited by fire watch personnel and documents th'e time.

Use of the system provides

prompt, accurate feedback on the performance of the Eire watch personneL.

. If discrepancies are

found, the matter is investigated and if

required, disciplinary action is taken.

As. noted in the Inspection Report 88-33,, this system was implemented prior to the issuance of the violation.

The fire watch program has been su'pplemented since the issuance of the violation with a revised pay scale for the fire watch personnel.

The previous pay scale did not provide any pay incentives for better performers.

This has been changed to allow more pay for those personnel who have demonstrated consistent, reliable performance and thereby increases the overall reliability of the program.

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In the past 11

months, three 10 percent samples of fire penetrations have been inspected..

Each 10 percent sample (680 penetrations) has revealed approximately 5-6 percent failures.

The majority of the failures are the result of improper initial 'installation and inspection.

As a result, the decision has been made to perform a

100 percent inspection (6800 penetrations).

It is felt that the penetration problem will then be resolved.

This inspection is expected to be completed by December 31, 1989.

MEM/H0-8802370/3/OS1

Date When Full Com liance will be Achieved:

1.

Full compliance was.achieved on. November 1, 1988.

2.

Full compliance is pending the 100 percent inspection and any required rework of penetrations

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This is expected to be completed by December 31, 1989.

MEM/H0-8802370/4/OS1.