ML18012A437

Responds to NRC 961107 Ltr Re Violations Noted in Insp Rept 50-400/96-09.Corrective Actions:Co Responsible for Inadvertent Filling & Resultant Dilution of Rwst,Was Counseled on Use of Error Prevention Techniques

ML18012A437
Person / Time
Site:	Harris
Issue date:	12/09/1996
From:	ROBINSON W R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-96-200, NUDOCS 9612130185
Download: ML18012A437 (11)

See also: IR 05000400/1996009

Text

CATEGORY j.REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION NBR:9612130185

DOC.DATE: 96/12/09 NOTARIZED:

NO FACIL:50-400

Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION

ROBINSON,W.R.

Carolina Power s Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 961107 ltr re violations

noted in insp rept 50-400/96-09.Corrective

Actions:CO

responsible

for inadvertent

filling&resultant dilution of RWST,was counseled on use of error prevention

techniques.

DISTRIBUTION

CODE'EOID COPIES RECEIVED'LTR.L

ENCI'SIZE'ITLE:

General (50 Dkt)-Insp Rept/Notice

of Violation Response DOCKET 05000400 NOTES:Application

for permit renewal filed.05000400 G RECIPIENT ID CODE/NAME PD2-1 PD I NTERNAL: ACRS ODIST C FILE.CENTE~NRR/DRCH7HHFB

NRR/DRPM/PERB

OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME LE,N AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

NUDOCS-ABSTRACT

OGC/HDS2 NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 D N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT.415-2083)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

Carolina Power&Light Company PO Box 165 New Hill NC 27562 William R.Robinson Vice President Harris Nuclear Plant DEC 9 1996 United States Nuclear Regulatory

Commission

ATTENTION:

Document Control Desk Washington, DC 20555~SERIAL: HNP-96-200

10 CFR 2.201 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400/LICENSE

NO.NPF-63 REPLY TO NOTICE OF VIOLATIONS (NRC INSPECTION

REPORT NO.50-400/96-09)

Dear Sir or Madam: Attached is Carolina Power&Light Company's reply to the Notice of Violations

described in Enclosure 1 of your letter dated November 7, 1996.Questions regarding this matter may be referred to Ms.D.B.Alexander at (919)362-3190.Sincerely, MGW Attachment

c: Mr.J.B.Brady (NRC Resident Inspector, HNP)Mr.S.D.Ebneter (NRC Regional Administrator, Region II)Mr.N.B.Le (NRR Project Manager, HNP)V6>ZXS0<85

9SS=09 PDR ADOCK 05000400 8 PDR r;-u't(,'g g State Road 113'ew Hill NC Tel 919 362-2502 Fax 919 362-2095

Document Control Desk HNP-96-200/

Page 2 REPLY TO NOTICE OF VIOLATIONS

NRC INSPECTION

REPORT NO.50-400/96-09

Technical Specification 6.8.1.a requires, in part, that procedures

shall be established, implemented, and maintained

covering the activities

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978,"Quality Assurance Program Requirements (Operations)." 1.Regulatory

Guide 1.33, Appendix A, Section 3.1, includes specific procedures

for the auxiliary feedwater system, for which the Condensate

Storage Tank (CST)is a safety-related water source.Licensee operating procedure OP-134, Condensate

System, Revision 7, contains in Section 8.3.2 specific steps for filling the CST.These steps include options to manipulate

either valve ICE-23 (Step 2)or valves IDW-490 and 1DW-486 (Step 3).Contrary to the above, on September 6, 1996, an operator manipulated

the wrong valve, 1DW-S, while attempting

to fill the CST.This error caused the subsequent

filling and dilution of the refueling water storage tank, and contributed

to the simultaneous

short-term inoperability

of the boration flow paths required by Technical Specification 3.1.2.2.Regulatory

Guide 1.33, Appendix A, Section 3 requires procedures

for startup, operation, and shutdown of safety-related

PWR systems.This requirement

is further implemented

by the licensee's

operations

management

manual procedure OMM-001, Operations-

Conduct of Operations, Revision 16.Procedure OMM-001 requires, in part, that instructions

for energizing, filling, draining, starting up, shutting down, and other instructions

appropriate

for operations

of systems related to safety shall be delineated

in system operating procedures.

Step 5.2.2.3.c directed personnel to use Attachment

2 of the procedure to document small changes to completed lineups (contained

in system operating procedures).

Contrary to the above, on September 29.1996, operators and shift management

failed to comply with the direction in OMM-001 by relying on an unreviewed

and unapproved

list of"spare" breakers to be turned off.This resulted in the de-energization

of a live circuit feeding a safety-related

radiation monitor and the subsequent

actuation of fuel handling emergency exhaust fan E-13B.This is a Severity Level IV violation (Supplement

I).

Document Control Desk HNP-96-200/

Page 3 De ia r d i i n fViolai The violation is admitted.e f eVi lati n:~Both examples of the above cited violation occurred due to personnel error.The Control Operator (CO)involved in example 1 failed to use error prevention

techniques

to verify that he was opening the correct valve.The Control Room Supervisor (CRS)involved in example 2 allowed the use of an informal, unapproved

list tolerate the circuit-breakers.

A common cause analysis was performed to address an adverse trend in personnel errors by operations

personnel.

Substandard

work practices and work standards have been the major contributor

to the adverse trend.These poor work practices and standards result from fundamental

attitudes and beliefs (culture)not being at a level required to support excellence

in all aspects of operator performance.

ive te ke a e u c ve Example 1: The CO responsible

for the inadvertent

filling and resultant dilution of the Refueling Water Storage Tank (RWST), was counseled on the use of error prevention

techniques.

The RWST was borated to within Technical Specification

limits on September 7, 1996.LER 96-020-00 was submitted on October 7, 1996 due to this event.Example 2: The breaker was returned to its normally closed position promptly after it was opened.The responsible

CRS was counseled on the use of formality and procedural

compliance

when directing the operation of plant components.

Directives

are in place to Operations

Unit Supervisors

and Superintendents

as interim corrective

actions until the common cause analysis corrective

actions are completed.

These directives

were included in CP&L's reply to notice of violation (NRC Inspection

Report No.50-400/96-07)

dated October 28, 1996 and address formality, use of procedures, generic job performance, expectations, shift briefings, shift staffing, and daily in-field observations

by supervisors.

ec'v, e sThatWi eTa en v h V'a ion Additional

actions are being developed to address the attitudes and beliefs (culture)within the Operations

Unit.A Near Term Improvement

Plan is being developed and will establish the framework for sustained, improved performance

in Operations.

This plan will be issued by December 31, 1996 and will include the following:

1.Existing strategies

and initiatives

for performance

improvement.

0

Document Control Desk HNP-96-200/

Page 4 ec've e W'eTae vi r V'ti n: (continued)

Focus Team initiatives.

A Focus Team has been established

and is comprised of operators in various working level positions.

The team is responsible

for identifying

critical improvement

opportunities

to effect a near-term step change in performance

and position the organization

for advancement

to"world class" performance.

The team will provide Operations

management

continuing

feedback on the effectiveness

of these initiatives.

The Focus Team is an essential link to improving the culture in Operations

because it will build ownership of problems and solutions at all levels in the organization.

3.A plan for benchmarking

work practices and culture with the best practices and behaviors within the Harris Plant, CP8cL, and as opportunity

allows, neighboring

utilities.

This plan will be periodically

assessed and revised as necessary.

Whe Ful i n eWa c'ev Full compliance

was achieved on September 7, 1996 for Example 1 and on September 29, 1996 for Example 2.e rtcdVi 1ai n8: Technical Specification 6.8.1.c requires that written procedures

shall be established, implemented, and maintained

covering Security Plan implementation.

Licensee procedure SP-005, Security Search and Contraband

Denial, Revision 5 partially implements

activities

covered by the licensee's

corporate security plan.Procedure section 7.0, Vehicle Searches, Step 7 specified that, following access by the vehicle, the gate and the vehicle barrier system active barrier shall be closed and returned to the blocking position.Contrary to the above, on September 13, 1996, an officer failed to ensure complete closure of protected area gate 1B following access by a vehicle.This resulted in a short-term

protected area opening (of which security personnel were unaware)in excess of the requirements

specified in the licensee's

corporate security plan, Physical Security and Safeguards

Contingency

Plan, Revision 0.This is a Severity Level IV Violation (Supplement

III).De i d i ion Vi at'he violation is admitted.

Document Control Desk HNP-96-200/

Page 5 es for he Vi lati n: The reason for the violation was human error, failure to comply with a procedural

requirement.

The assigned Nuclear Security Officer failed to ensure that an electrically

operated Protected Area gate was properly closed before turning his attention, and his view, to a different task.rrective te Ta e n ul Achieve The gate was secured immediately

following discovery on September 13, 1996.A Security Incident/Complaint

Report was prepared documenting

the circumstances

surrounding

the incident.A Condition Report (CR)was written.Investigation

determined

the cause of the event to be human error.The event was documented

in the HNP Safeguards

Event Log in accordance

with the provisions

of 10 CFR 73.71.The Nuclear Security Officer involved in the procedural

noncompliance

has received disciplinary

counseling

and corrective

instruction.

A training document was prepared and addressed with members of each of the four Security Platoons to reiterate procedural

requirements

related to the integrity of Protected Area gates.The training document[Training Topic"Operation

and Opening Protected Area Barrier Gates"]provided an overview of the circumstances

involved in the incident and contained extracts from applicable

security procedures

including:

1.Monitoring

Protected Area gate activity from an alarm station.2.Integrity of the Vehicle Barrier System (VBS).3.Responsibility

assignment

for maintaining

the integrity of the Protected Area barrier.4.Maximum permissible

size of openings within the Protected Area barrier.5.Method of securing the Protected Area gate when it is not attended by a Security Officer.6.Prerequisite

security manning before a Protected Area gate may be opened.ec've e T~Wil e ken v idFu erV'o further actions required.ae'ance Wa chieved: Full compliance

was achieved on September 13, 1996 when Protected Area gate 1B was secured following discovery.

Document Control Desk HNP-96-200/

Page 6 Re orted Violati n 10 CFR 50.65 (b)establishes

that the scope of the maintenance

rule monitoring

program shall include safety-related

structures, systems, or components

that are relied upon to remain functional

during and following design basis events to ensure the integrity of the reactor coolant pressure boundary, the capability

to shut down the reactor and maintain it in a safe shutdown condition, and the capability

to prevent or mitigate the consequences

of accidents that could result in potential offsite exposure comparable

to the 10 CFR Part 100 guidelines;

and non-safety

related structures, systems or components

that are relied upon to mitigate accidents or transients

or are used in the plant emergency operating procedures, or whose failure could cause a reactor scram or actuation of a safety-related

system.Procedure ADM-NGGC-0101, Maintenance

Rule Program, Revision 3, implements

10 CFR 50.65 and provides maintenance

rule implementation.

instructions.

Section 9.3.1, under scoping, directed personnel to obtain systems lists from the Equipment Data Base System (EDBS)and supply to the Expert Panel for evaluation.

Attachment

1, List of CP&L Maintenance

Rule Systems, lists the EDBS system name, system number, and the expert panel determination.

The expert panel system determinations

were loaded into EDBS with all components

in each system receiving the determination

for the system.Contrary to the above, as of August 16, 1996, the licensee had not included all systems and components

within the scope of the rule as required.Boric Acid filter isolation valve 1CS-559 was designated

in EDBS as not within the scope of the maintenance

rule, even though it is in the emergency boration flow path which is used to mitigate accidents.

The component had been listed in EDBS under a system that was not scoped within the maintenance

rule.The licensee's

review also found multiple components

in each of nine systems that were not scoped correctly in EDBS because they were listed in incorrect systems.This is a Severity Level IV Violation (Supplement

I).e'a rAd'Vi lofti n: The violation is admitted.e nfo heV'The violation resulted from a failure to identify that specific components

in maintenance

rule (MR)systems were loaded in the EDBS under other non-MR systems.This occurred due to an oversight during development

of a site-wide action item list to track MR implementation

actions and inappropiate

use of EDBS as a MR tool.EDBS was developed using system boundaries

from initial system startup.A MR Expert Panel determined

MR scoping using guidance in NUMARC 93-01.Although the scoping was performed at the"EDBS system" level, it was recognized

that there might be quality class"A" components

in non-MR systems which could impact a MR function and would need to be included.Quality class"A" is the designator

used for safety related components

in EDBS.However, no formal action item was created to ensure that such components

were identified.

Document Control Desk HNP-96-200/

Page 7 ectve te sTa e n e I c ieved: On August 8, 1996, quality class"A" components

listed under non-MR systems were re-coded in EDBS to be identified

as within the scope of the MR.Although some class"A" components

do not serve a safety related function, this was completed as an interim corrective

action to ensure these components (approximately

1200)will be treated as MR for maintenance

purposes until further evaluation

can be completed.

Further review of these 1200 items revealed that 152 (41 components, 111 piping segments)should be relocated to specific MR systems in the EDBS database.These changes were completed on October 30, 1996.Based on this violation and the preliminary

results of initial NRC MR baseline inspections

at other plants, Harris Nuclear Plant conducted a MR self assessment.

The assessment

was completed on December 5, 1996.Preliminary

results of the assessment

indicate other items which need further review to ensure full compliance

with the MR.e ive.e Tha W'en v'd u herVi ai Some of the 1200 items were listed correctly under non-MR systems, but could potentially

impact MR functions.

These components'unctions

will be validated and presented to the Expert Panel for formal MR inclusion by February 28, 1997.Additional

guidance will be provided regarding the use and limitations

of EDBS as a MR tool by February 28, 1997.Components

which were re-coded as MR on August 8, 1996 which are determined

by further evaluation

to have no impact on MR functions will be returned to non-MR designation

in EDBS by March 31, 1997.W'a ce W'll e c ieve Items from the MR self assessment

discussed above which could result in noncompliance

will be resolved prior to February 28, 1997 or a supplemental

response to this violation will be provided with an updated schedule for resolution.