ML18012A847

LER 97-018-00:on 970701,determined That Plant Procedures Had Not Received Proper Reviews & Approvals.Caused by Failure to Comply W/Plant Administrative Procedure AP-006.Counseled Involved individuals.W/970731 Ltr

ML18012A847
Person / Time
Site:	Harris
Issue date:	07/31/1997
From:	Donahue J, Ellington M CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-97-143, LER-97-018, LER-97-18, NUDOCS 9708060308
Download: ML18012A847 (8)

Text

CATEGORY 1 REGULATO Y INFORMATION DISTRIBUTION STEM (RIDS)"~ACCESGION MBR:9708060308 DOC.DATE: 97/07/31 NOTARIZED:

NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME-=-., AUTHOR AFFILIATION ELLINGTON,M.

.Carolina'ower

&Light Co.DONAHUE,J.W.

, Carolina Power&Light Co.RECIP.NAME RECIPIENT'AFFILIATION DOCKET 05000400 05000400 g 0-

SUBJECT:

LER 97-018-00:on 970701,determined that plant procedures had not received proper reviews&approvals.

Caused by failure to comply-w/plant administrative procedure AP-006.Involved site mgt counseled.W/970731 ltr.DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR I ENCL: SIZE:.TITLE: 50.73/50.9 Licensee Event Report (LER), Incident Rpt, etc.V NOTES:Application for permit renewal filed.RECIPIENT ID CODE/NAME PD2,.-1 PD INTERNAL: ACRS AEOD/SPD/RRAB NRR/DE/ECGB NRR/DE/EMEB NRR/DRCH/HICB NRR/DRCH/HQMB NRR/DSSA/SPLB RES/DET/EIB EXTERNAL: L ST LOBBY WARD NOAC POORE,W.NRC PDR COPIES LTTR ENCL 1-1 1 1 1 1 1 1 1 1=1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME ROONEYEV RAB ILE CENTE NR E EELB, NRR/DRCH/HHFB

.NRR/DRCH/HOLB NRR/DRPM/PECB NRR/DSSA/SRXB RGN2 FILE 01 LITCO BRYCEgJ H NOAC QUEENEREDS NUDOCS FULL TXT COPIES LTTR ENCL 1, 1 2 2 1 1 1 1 1 1 1.1 1 1 1 1 1 1 1 1 1 1 1 1 R 0 NOTE TO ALL"RZDS" RECZPZENTSZ PLEASE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK/ROOM OWPN SD-5(EXT.415-2083)TO ELZMZNATE YOUR NAME PROM DZSTRZBUTZON LZSTS FOR DOCUMENTS YOU DON'T NEEDl FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25 Carolina Power&Light Company Harris Nuclear Plant PO Box 165 New Hill NC 27562 JUL 31 1997 U.S.Nuclear Regulatory Commission ATTN: NRC Document Control Desk Washington, DC 20555 Serial: HNP-97-.143 10CFR50.73 SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1-DOCKET NO.50-400 LICENSE NO.NPF-63 LICENSEE EVENT REPORT 97-018-00 Sir or Madam:~g'In accordance with Title",10.to the.Code of Federal Regulations,lthe enclosed Licensee Event Report is submitted.-'This

'report de'scribes operation with procedures that were not properly reviewed and approved.Sincerely, J.W.Donahue Director of Site Operations Harris Plant MSE/mse~6M'nclosure~~GG ,c: ':.'r,'-J.'!B.:"-Brady (HNP Senior.NRC:Resident)'.';;:

".:.--..:::

.-:;...:;,,:

.;.:.i."..:.:..'.:Mr L'.A.Reyes'(NRC Regional Administrator;.Region:11);::

Mr.V.L.Rooney (NRC-NRR Project Manager)IIIIUlllllllllllHIIIIIIIIUILIUIIU 5413 Shearon Harris Road New Hill NC j~

NRC FORM 366, H-35)r e U.S.'NUCLEAR REGULATORY COMMISSION LXCENSEE EVENT REPORT (LER){SBB reverse for required number of digits/characters for each block)APPROVED BY OMB NO.31 500104 EXPIRES 0430lss ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS MANDATOR INFORMATION COLLECTION REOUEsnf 50.0 HRS.REPORTED LESSONS LEARNE ARE INCORPORATED INTO THE UCENSING PROCESS AND FED BACK TO INDUSTRY FORWARD COhNFMS REGARDUIG BURDEN ESTIMATE TO THE INFORMATION AN RECORDS MANAGEMENT BRANCH IT41 F33), U.S.NUCLEAR REGULATOR COMMISSION, WASIENGTON DC 205550001 ANDTO THE PAPERWORK REDUCllo PROJECT (31500104), OFFlCE OF MANAGIJJtENT AND BUDGET, WASHINGTON, 209XL FACIUTY NAME (I)Shaaron Harris Nuc(ear Plant, Unit-1 TITLE I4)Operation with procedures not properly reviewed and approved DOCKET NUMBER{2)50-400 PAGE (3)1 OF3 MBNTN DAY YEAR 07 01 97 OPERATING MODE{9)POWER LEVEL (10)SEDUENTIAL REVISION NUMBER NUMBER 97-018-00 20.2201(b) 20.2203(a)

(2)(i)20.2203(a) l2)(iii)20.2203(a)

(2)(iv)DAY'YEAR 07 31 97 20.2203(a)

(3)(ii)60.36{c)l1)60.36(c)l2)20.2203(a)

(2)(v)FACILITY NAME FACILITY NAME 60.73(a)l2)(i)60.73(a)(2)

{iii)60.73(a)(2)(v)60.73(a)(2)(vii)DOCKET NUMBER DOCKET NUMBER 05000 60.73(a)(2)(viii)73.71 OTHER Specify In Abstract below or in NRC Form 366A NAME Mark Ellington Senior Analyst-Licensing TELEPHONE NUMBER (Inoerde Ares Code)(919)362-2057 CAUSE SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPROS CAUSE SYSTEM MANUFACTURER REPORTABLE TO NPRDS YES{If yes, complete EXPECTED SUBMISSION DATE).X NO EXPECTED SUBMISSION DATE{16)MONTH DA YEAR ABSTRACT{Limit to 1400 spaces, i.e., approximately 16 single-spaced typewritten lines){16)On July 1, 1997, with the plant at approximately 100%power in Mode 1, an investigation determined that some Harris Nuclear Plant (HNP)procedures had not received proper reviews and approvals.

Specifically, approximately 150 temporary procedure changes affecting over 100 procedures were not reviewed and approved within 14 days in accordance with Technical Specification (TS)6.8.3 and 6.5.1.Additionally, many of these procedures were used to operate the plant without the required TS review and approval.The cause of this TS violation is failure to comply with plant administrative procedure AP-006.Contributing factors were: (1)A misunderstanding of the basis of the requirements in the AP-006 by site personnel.

(2)Inadequate management involvement once the problem was brought to management's attention as evidenced by not stopping the Handwritten Revision non-intent process once a problem was identified.

The following corrective actions have been performed:

(1)HNP procedures identified as deficient have been properly reviewed and approved in accordance with TS, (2)Involved Site Management has been counseled that procedure non-compliance must be prevented and promptly corrected upon discovery, (3)Communications to appropriate site personnel have been made on how AP.-006 implements TS requirements, (4)AP-006 has been revised to clarify implementation of TS requirements and (5)The Supervisor-Operations Support, involved in this event, has been disciplined by Plant Management A comprehensive review of the procedure change and review process will be completed by 9/1/97.

RC FORM 3EEA 495)LICENSEE EVENT BEPOBT (LEB)TEXT CONTINUATION ILS.NUCLEAR REGULATORT COMMISBIO FACILITY NAME (I)Shearon Harris Nuclear Plant-Unit 1 EXT Pinero oOoalt ooqoind, mooiRRoooorooyiieolHRC Faao3GRRl I)7)DOCKET 50400 LER NUMBER IB)BEOUENTUL REVISION NUMBER NUMBER 97-018-00 PAGEIB)2 OF 3 VENT DESCRIPTION:

n July 1, 1997 with the plant at approximately 100%power in mode 1, an investigation determined some HNP procedures ad not received the required TS reviews and approvals.

Specifically, approximately 150 temporary procedure changes fecting over 100 procedures were not reviewed and approved within 14 days in accordance with TS 6.8.3.Additionally, any of these procedures were used to operate the plant without the required TS review and approval.e plant definition for a temporary procedure change is a change that will eventually be removed from the procedure.

ANSI 18.7 definition is somewhat different in that temporary procedure changes could be incorporated, as appropriate, into the ext revision to the procedure.

J~S 1994 AP-006,"Procedure review and approval," was revised to include permanent, Handwritten Revision non-intent rocedure changes that could take advantage of the 14-day limit for review and approval described in TS for temporary hanges to procedures.

AP-006 was revised to require the reviews and approvals described in TS for temporary changes to rocedures, however the procedure did not reference TS.Consequently', involved site personnel did not understand that andwritten Revision non-intent procedure changes were in fact temporaiy procedure changes as referenced in TS and ANSI 18.7.uring Refueling Outage 7 (RFO7), Handwritten Revision non-intent procedure changes were processed without review and pproval within 14 days as required by AP-006, especially in the Operations organization.

The Operations Procedure oordinator informed his supervisor (Supervisor

-Operations Support or S-OS)that the 14-day limit for review and approval f Handwritten Revision non-intent procedure changes would not be met due to the large volume (39)to be processed.

The ourse of action determined by the S-OS was to direct the procedure coordinator to focus on temporary changes to procedures ince they were required by TS and document the Handwritten Revision non-intent procedure changes that went overdue by a ondition report.The situation grew worse due to mis-communication between the S-OS and site management.

The S-OS nformed site management of the problem and his course of action.At this time, he requested relief from the 144ay AP406 uirement to perform required reviews and approvals of Handwritten Revision non-intent procedure changes.The relief was ot granted, but no other course of action was directed or suggested.

Without further guidance, the S-OS concluded his course f action was acceptable to plant management.

s a result over 125 Handwritten Revision non-intent procedure changes affecting approximately 90 Operation's procedures ere not properly reviewed and approved as required by TS 6.8.3.Additionally, many of these procedures were used by perations without being properly reviewed and approved.fter combining procedure change deficiencies from other plant organizations with the Operations organization, the total umber of procedure changes that did not receive proper review and approval was approximately 150, affecting pproximately 100 procedures.

Some of these violations occurred in 1996, but were not recognized as TS violations at that me.AUSE: ailure to comply with plant administrative procedure, AP406, caused these events.Contributing factors were: (1)A sunderstanding of the basis of the requirements in the AP-006 by site personnel and (2)Inadequate management volvement once the problem was brought to management's attention as evidenced by not stopping the Handwritten evision non-intent process once a problem was identified.

AFETY SIGNIFICANCE:

ere were no safety consequences associated with this event.Subsequent review and approval of procedures specified in this ER did not reveal operation of the plant outside its licensing or design basis.Additionally, the procedure changes did not equire alteration as a result of the subsequent 10 CFR 50.59 reviews.

ra'r.lNRC FORM 344A'4-951

<<LICENSEE EVENT REPORT (LEB)TEXT CONTINUATION ILS.NUCLEAR REGULATORY COMMSSIO<<FACILITY NAME III DOCKET LER NUMBER I4)<<PAGEOI Shearon Harris Nuclear Plant~Unit 81 TEXT Ilhooco cPocoiscrqo4NL ocoadfitkorl cero'mollllIC farm 36Ql (17j 50400 SEOUENTUIL REVSION NUMRER NUMRER 3 OF3 97-018-00 3.PREVIOUS SIMIL'AR EVENTS: r No prev'ious HNP.events have been reported related to missing the'144ay TS requirement for temporary changes to=procedures.

r II CORRECTIVE ACTIONS COMPLETED:

~~l 1'..r.HNP procedures identified as deficient have been properly reviewed and approved in accordance with TS.2.Involved Site Management has been counseled that procedure noncompliance must be prevented and promptly corrected upon discovery.

'Communications to appropriate site personnel have been made on how AP-006 implements TS requirements.

~~4.=-'P-006 has been'revised to clarify implementation'of TS requirements..

5.The Supervisor-Operations Support, involved in this event, was disciplined by Plant Management.

1 CORRECTIVE ACTIONS PLANNED: r 1.A comprehensive review of the procedure change and review process will be completed by 9/1/97.

0 C~1:l.