ML12325A383

IR 12-04 Errata

ML12325A383
Person / Time
Site:	Harris
Issue date:	11/20/2012
From:	Randy Musser NRC/RGN-II/DRP/RPB4
To:	Hamrick G Carolina Power & Light Co
Shared Package
ML12325A324	List: IR 05000400/2012004 ML12325A383
References
IR-12-004
Download: ML12325A383 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 November 20, 2012 Mr. George T. Hamrick Vice President Shearon Harris Nuclear Power Plant Carolina Power and Light Company P.O. Box 165, Mail Code: Zone 1 New Hill, NC 27562-0165

SUBJECT:

ERRATA - SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000400/2012004 AND 05000400/2012502

Dear Mr. Hamrick:

On October 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued the subject inspection report for Shearon Harris Nuclear Power Plant, ADAMS accession ML12299A433. In reviewing this report it was noted that in the Summary of Findings and in section 4OA2.4 the cross-cutting aspect of the non-cited violation of Technical Specification 6.8.4, Procedures, was incorrectly defined. Accordingly, we have revised page 3 of the Summary of Findings section and page 21 of Inspection Report 05000400/2012004 and 05000400/2012502, in order to document the necessary changes. Please replace pages 3 of the Summary of Findings and page 21 of the original report with the pages enclosed.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). An ADAMS package which contains both the original report and this errata is available at ML12325A324. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/readingrm/adams.html (The Public Electronic Reading Room).

I apologize for any inconvenience this error may have caused. If you have any questions, please contact me at (404) 997-4603.

Sincerely,

/RA/

Randall A. Musser, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket No.: 50-400 License No.: NPF-63

Enclosure:

As stated

_ML12325A383_______________ G SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRP RII:DRP SIGNATURE /RA/ /RA/

NAME JWorosilo RMusser DATE 11/20/2012 11/20/2012 11/ /2012 11/ /2012 11/ /2012 11/ /2012 11/ /2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO G. Hamrick 2 cc w/encl: R. Keith Holbrook Manager, Support Services Brian Bernard Shearon Harris Nuclear Power Plant Manager, Nuclear Services and EP Electronic Mail Distribution Nuclear Protective Services Shearon Harris Nuclear Power Plant David H. Corlett Electronic Mail Distribution Supervisor Licensing/Regulatory Programs Brian C. McCabe Progress Energy Manager, Nuclear Oversight Electronic Mail Distribution Shearon Harris Nuclear Power Plant Progress Energy David T. Conley Electronic Mail Distribution Senior Counsel Legal Department George T. Hamrick Progress Energy Vice President Electronic Mail Distribution Carolina Power and Light Company Shearon Harris Nuclear Power Plant Donna B. Alexander Electronic Mail Distribution Manager, Nuclear Regulatory Affairs (interim)

Lara S. Nichols Progress Energy Deputy General Counsel Electronic Mail Distribution Duke Energy Corporation Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge M. Christopher Nolan 2300 N. Street, NW Director - Regulatory Affairs Washington, DC 20037-1128 General Office Duke Energy Corporation Joseph W. Donahue Electronic Mail Distribution Vice President Nuclear Oversight Robert J. Duncan II Progress Energy Senior Vice President Electronic Mail Distribution Progress Energy Electronic Mail Distribution W. Lee Cox, III Section Chief Sean T. O'Connor Radiation Protection Section Manager, Support Services N.C. Department of Environmental Shearon Harris Nuclear Power Plant Commerce & Natural Resources Electronic Mail Distribution Electronic Mail Distribution Donald L. Griffith Public Service Commission Training Manager State of South Carolina Shearon Harris Nuclear Power Plant P.O. Box 11649 Progress Energy Columbia, SC 29211 Electronic Mail Distribution (cc: w/encl. continued)

G. Hamrick 3 cc: w/encl. contd Chairman North Carolina Utilities Commission Electronic Mail Distribution Terrence E. Slake Manager Nuclear Plant Security Shearon Harris Nuclear Power Plant Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 Chair Board of County Commissioners Wake County P.O. Box 550 Raleigh, NC 27602 Ernest J. Kapopoulos Jr.

Plant General Manager Carolina Power and Light Company Shearon Harris Nuclear Power Plant Electronic Mail Distribution Chair Board of County Commissioners Chatham County P.O. Box 1809 Pittsboro, NC 27312 Senior Resident Inspector U.S. Nuclear Regulatory Commission Shearon Harris Nuclear Power Plant U.S. NRC 5421 Shearon Harris Rd New Hill, NC 27562-9998

G. Hamrick 4 Letter to George T. Hamrick from Randall A. Musser dated November 20, 2012.

SUBJECT:

ERRATA - SHEARON HARRIS NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000400/2012004 AND 05000400/2012502 Distribution w/encl:

J. Baptist, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMBrunswick Resource

3 represent an actual loss of function of at least a single train for greater than the Allowed Out-of-service Time (AOT) or two separate safety systems out-of-service for greater than the AOT, did not result in a loss of safety function of one or more non-Technical Specification (TS) trains of equipment designated as risk significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic snubbers, flooding barriers, tornado doors). The finding had a cross-cutting aspect of Evaluation of Identified Problems, as described in the Corrective Action component of the Problem Identification and Resolution cross-cutting area, because the licensee did not implement adequate corrective actions to prevent recurrence of unanalyzed material left in containment following the performance of OST-1081 (P.1(c)). (Section 1R18)

Green: A self-revealing Green NCV of Technical Specification (TS) 6.8.1, Procedures, was identified for the licensees failure to develop an adequate procedure for maintenance on an oil filled cable. Specifically, the licensee failed to provide adequate instructions to prevent causing additional damage to the cable which resulted in the lockout of the B Startup Transformer (SUT) on June 25, 2012. This also resulted in unavailability of the preferred power source for the B safety related equipment for over two days. As corrective actions, the licensee repaired the cable, restored oil pressure and returned the B SUT to its normal standby configuration. Additionally, the licensee performed an investigation which concluded that the cable had been damaged at the site of a previous repair when it was handled during maintenance. The issue was placed into the CAP as AR #545920.

The licensees failure to develop an adequate procedure to ensure proper handling of the cable and prevent inadvertently causing damage was a performance deficiency. The performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating Systems cornerstone, and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it resulted in the lockout of the B SUT and unavailability of the preferred power source for the B safety related equipment for over two days. Using IMC 0609, Significance Determination Process, this finding was determined to be of very low safety significance because it was not a design or qualification deficiency, did not represent an actual loss of function of at least a single train for greater than the TS AOT or two separate safety systems out-of-service for greater than the AOT, did not result in a loss of safety function of one or more non-TS trains of equipment designated as risk significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic snubbers, flooding barriers, tornado doors). The finding had a cross-cutting aspect of complete, accurate and up-to-date procedures, as described in the Resources component of the Human Performance cross-cutting area, because the licensee did not develop adequate procedures to prevent further damage while performing maintenance on the SUT cables (H.2(c)). (Section 4OA2)

Enclosure

21 Analysis: The licensees failure to develop an adequate WO in accordance with NGGM-IA-0003 to ensure proper handling of the cable and prevent inadvertently causing damage was a performance deficiency. The performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Mitigating System cornerstone, and it affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it resulted in the lockout of the B SUT and unavailability of the preferred power source for the B safety related equipment for over two days. Using IMC 0609, Significance Determination Process, this finding was determined to be of very low safety significance because it was not a design or qualification deficiency, did not represent an actual loss of function of at least a single train for greater than the AOT or two separate safety systems out-of-service for greater than the AOT, did not result in a loss of safety function of one or more non-TS trains of equipment designated as risk significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g., seismic snubbers, flooding barriers, tornado doors). The finding had a cross-cutting aspect of complete, accurate and up-to-date procedures, as described in the Resources component of the Human Performance cross-cutting area, because the licensee did not develop adequate procedures to prevent further damage while performing maintenance on the SUT cables (H.2(c)).

Enforcement: TS 6.8.1, Procedures, requires that written procedures shall be established, implemented, and maintained, covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Section 9 of Appendix A of Regulatory Guide 1.33 requires procedures for maintenance that can affect the performance of safety related systems. In order to perform work in the switchyard, the licensee uses NGGM-IA-0003 to develop work orders. NGGM-IA-0003 requires, in part, that work packages to support scheduled transmission maintenance activities contain sufficient technical information and guidance to reduce the potential for errors. Contrary to this requirement, the licensee failed to establish an adequate procedure for maintenance on the A phase cable for the B SUT, in that WO #2015394-11 failed to provide any guidance on the proper handling of this unique type of cable and resulted in inadvertent damage. This caused the cable to fail less than one week later resulting in the lockout of the B SUT and unavailability of the preferred power source for the B safety related equipment for over two days. As corrective actions, the licensee repaired the cable, restored oil pressure and returned the B SUT to its normal standby configuration. Additionally, the licensee performed an investigation which concluded that the cable had been damaged at the site of a previous repair when it was kinked while performing WO #2015394-11. Because the finding is of very low safety significance and has been entered into the CAP as AR #545920, this violation is being treated as a Green NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy: NCV 05000400/2012004-02, B Startup Transformer Lockout due to Loss of Oil Filled Cable Pressure.

Enclosure