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{{Adams
#REDIRECT [[HNP-12-105, Reply to Notice of Violation; EA-12-132, NRC Inspection Report 05000400-12-010]]
| number = ML12312A126
| issue date = 11/01/2012
| title = Reply to Notice of Violation; EA-12-132, NRC Inspection Report 05000400-12-010
| author name = Hamrick G
| author affiliation = Duke Energy Corp
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/RGN-II
| docket = 05000400
| license number =
| contact person =
| case reference number = EA-12-132, HNP-12-105, IR-12-010
| document type = Letter, Licensee Response to Notice of Violation
| page count = 4
}}
See also: [[see also::IR 05000400/2012010]]
 
=Text=
{{#Wiki_filter: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.
}}

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