ML12312A126
| ML12312A126 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/01/2012 |
| From: | Hamrick G T Duke Energy Corp |
| To: | Document Control Desk, NRC/RGN-II |
| References | |
| EA-12-132, HNP-12-105, IR-12-010 | |
| Download: ML12312A126 (4) | |
See also: IR 05000400/2012010
Text
kDukeW EnergyGeorge T. HamrickVice PresidentHarris Nuclear Plant5413 Shearon Harris RdNew Hill NC 27562-9300919-362-2502November 1, 2012Serial: HNP-12-105ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Shearon Harris Nuclear Power Plant, Unit IDocket No.50-400Subject: Reply to Notice of Violation; EA-12-132NRC Inspection Report 05000400/2012010Ladies and Gentlemen:Enclosed is Carolina Power & Light Company's reply to the Notice of Violation contained in theenclosure 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- 12-132cc:Mr. J. D. Austin, NRC Sr. Resident Inspector, HNPMs. A. T. Billoch Col6n, NRC Project Manager, HNPMr. V. M. McCree, NRC Regional Administrator, Region IIarc)
Document Control DeskEnclosure to HNP-12-105 Page 1 of 3REPLY TO NOTICE OF VIOLATION; EA-12-132NRC INSPECTION REPORT 05000400/2012010Reported Violation A:10 CFR 50.54(q) requires, in part, that a licensee authorized to operate a nuclear power reactorshall follow and maintain in effect emergency plans which meet the standards of 10 CFR50.47(b).10 CFR 50.47(b)(8) requires that adequate emergency facilities and equipment to support theemergency response are provided and maintained.10 CFR 50, Appendix E, Section IV.E.8 (2011 version) states, in part, that the emergencyfacilities shall include licensee onsite technical support center and an emergency operationsfacility from which effective direction can be given and effective control can be exercised duringan emergency.The Harris Nuclear Plant Emergency Plan, Section 3.1, revision 57, states in part that adequateemergency facilities, communications, and equipment to support emergency response areprovided and maintained.Contrary to the above, on several occasions between August 4, 2009, and November 9, 2011, thelicensee failed to maintain adequate emergency facilities and equipment to support emergencyresponse. Specifically, the Emergency Operations Facility (EOF) normal and emergencyventilation system was in a degraded state and/or removed from service, for extended periods oftime.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 toensure the functionality and reportability requirements for the Emergency Response Facilitiesdid 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, Prioritizationand Classification on September 10, 2012, to ensure that equipment that is important tofacility readiness is assigned a priority that considers its importance. The result of thisaction is that EOF equipment repairs are now integrated into the site's work managementsystem.2. Issued procedure PLP-717, Equipment Important to Emergency Preparedness and EROResponse on October 11, 2012, to ensure that when equipment important to EmergencyPreparedness (EP) is out of service for maintenance (planned or unplanned), or is in a Document Control DeskEnclosure to HNP- 12-105 Page 2 of 3degraded condition, the correct restoration priority is assigned; compensatory measures areimplemented; 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 technicalrequirements and administrative controls needed for the EOF and Technical Support Center toensure performance of design and licensing basis functions. This will include design review anddocumentation, procedures, and line ownership. This action is currently scheduled to becompleted in December 2012.Date When Full Compliance Will Be Achieved:Full compliance was achieved November 9, 2011, upon completion of testing following repairson EOF emergency ventilation isolation damper D-3. The additional actions stated above willfurther 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 allcases within eight hours of the occurrence of any event that results in a major loss of emergencyassessment capability, offsite response capability, or offsite communications capability (e.g.,significant portion of control room indication, Emergency Notification System, or offsitenotification system).Contrary to the above, on several occasions between August 4, 2009, and November 9, 2011, thelicensee failed to notify the NRC within eight hours of the occurrence of a major loss ofemergency assessment capability. Specifically, the licensee failed to report that the EOF normaland emergency ventilation system was in a degraded state, and/or removed from service, forextended 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 andreportability requirements for the Emergency Response Facilities did not meet the standardsestablished 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 toEmergency Response Facilities. As a result, HNP's reportability threshold is aligned withNRC requirement .WDocument Control DeskEnclosure to HNP-12-105 Page 3 of 32. Issued procedure PLP-717, Equipment Important to Emergency Preparedness and EROResponse on October 11, 2012, to provide guidance to the shift manager to ensure thatwhen equipment important to EP is out of service or degraded, the condition is evaluatedfor reportability in accordance with procedure AP-617. The results of this action are aprocedurally driven connection between equipment important to EP and reportabilityguidance.Corrective Steps That Will Be Taken:To preclude further noncompliance, an action is underway to document the technicalrequirements and administrative controls needed for the EOF and Technical Support Center toensure performance of design and licensing basis functions. This will include design review anddocumentation, procedures, and line ownership. This action is currently scheduled to becompleted in December 2012.Date When Full Compliance Will Be Achieved:Full compliance was achieved on October 30, 2012, when HNP submitted to the NRCOperations Center a supplement to event notification report EN-47775 for past periods where theEOF was in a non-functional status. The additional actions stated above will further enhance ourability to maintain compliance.