ML20134J855

Notice of Violation from Insp on 960901-1012.Violations Noted:Operators & Shift Mgt Failed to Comply W/Direction in OMM-001 by Relying on Unreviewed & Unapproved List of Spare Breakers to Be Turned Off

ML20134J855
Person / Time
Site:	Harris
Issue date:	11/07/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18012A425	List: ML20134J855
References
50-400-96-09, 50-400-96-9, NUDOCS 9611180105
Download: ML20134J855 (3)

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. NOTICE OF VIOLATION Carolina Power & Light Company Docket No. 50 400 Shearon Harris Unit 1 License No. NPF-63 i

l During an NRC inspection conducted from September 1 through October 12, 1995,  :

violations of NRC requirements were identified. In accordance with the  :

" General Statement of Policy and Procedure for NRC Enforcement Actions," ,

NUREG 1600, the violations are listed below:  !

A. Technical S mcification 6.8.1.a requires, in part, that procedures shall be establis1ed, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2.

February 1978, " Quality Assurance Program Requirements (Operations)."

i 1. Regulatory Guide 1.33 Appendix A. Section 3.1, includes s meific

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procedures for the auxiliary feedwater system, for which t1e i Condensate Storage Tank (CST) is a safety related water source.

i Licensee operating procedure OP 134. Condensate System, i

Revision 7, contains in Section 8.3.2 specific steps for filling the CST. These steps include options to manipulate either valve l ICE-23 (Step 2) or valves 1DW 490 and 1DW 486 (Step 3).  :

I Contrary to the above, on September 6, 1996, an operator i manipulated the wrong valve,1DW 5, while attempting to fill the l 4

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 l l Technical Specification 3.1.2.2. '

4 2. Regulatory Guide 1.33, Appendix A Section 3 requires procedures  !

for startup, operation, and shutdown of safety related PWR 4

systems. This requirement is further implemented by the licensee's operations management manual procedure OMM 001, i Operations Conduct of Operations, Revision 16.

Procedure OMM 001 requires, in part, that instructions for

energizing, filling, draining, starting up, shutting down, and l 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 l 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 l

Enclosure 1  !

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l 9611180105 961107 PDR ADOCK 05000400 e PDR

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! . CP&L 2 i

i subsequent actuation of fuel handling building emergency exhaust '

fan E-13B.

i This is a Severity Level IV violation (Supplement 1).

B.  !

j Technical be establis1ed, S)ecification implemented, 6.8.1.c andre!uires m intained thatcovering written procedures Security Planshall  !

implementation.  !

Licensee i

RevisionkrocedureSP005,SecuritySearchandContrabandDenial, partially implements activities covered by the licensee's  !

i corporate security plan. Procedure section 7.0, Vehicle Searches,  !

! Step 7 s)ecified that, following access by the vehicle, the gate and the  :

vehicle aarrier system active barrier shall be closed and returned to  !

j the blocking position. )

t i Contrary to the above On September 13, 1996, an officer failed to I ensure complete closure of protected area gate IB following access by a i vehicle This resulted in a short term protected area opening (of which  !

3 securit personnel were unaware) in excess of the requirements specified  :

in the icensee's corporate security plan. CP&L Physical Security and i Safeguards Contingency Plan, Revision 0. l j.

This is a Severity Level IV Violation (Supplement III). .

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C. 10 CFR 50.65 (b) establishes that the scope of the maintenance rule l monitoring program shall include safety related structures, systems, or  !

components that are relied upon to remain functional during and i i following design basis events to ensure the integrity of the reactor i 3 coolant pressure boundary, the capability to shut down the reactor and i i maintain it in a safe shutdown condition, and the capability to prevent  :

or mitigate the consequences of accidents that could result in potential  !

3 offsite exposure comparable to the 10 CFR part 100 guidelines; and non-  ;

4 safety related structures, systems or components that are relied upon to l

! mitigate accidents or transients or are used in the plant emergency  ;

[ operating procedures, or whose failure could prevent _ safety related ,

structures, systems, and components from fulfilling their safety related l 1 function, or whose failure could cause a reactor scram or actuation of a  !

{ safety-related system. l

! Procedure ADM NGGC 0101, Maintenance Rule Program, Revision 3,  !

. implements 10 CFR 50.65 and provides maintenance rule implementation i l instructions. Section 9.3.1, under scoping, directed personnel to  ;

. obtain systems lists from the Equipment Data Base System (EDBS) and i

supply to the Expert Panel for evaluation. Attachment 1. List of CP&L  !

Maintenance Rule Systems, lists the EDBS system name, system number, and l 1 the expert panel determination. The expert panel system determinations )

1 were loaded into EDBS with all components in each system receiving the determination for the system.

i 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 i~

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. CP&L 3 i required. Boric Acid filter isolation valve ICS 559 was designated in j

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).

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Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington, D.C.

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked " Reply to a Notice of

~ Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed corres addresses the required response.pondence, If an adequateif the correspondence reply adequately is not received within the time specified in this Notice, an order or Demand for Information may be ,

issued as to why the license should not be modified, suspended, or revoked, or  !

why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

i Because your res)onse will be placed in the NRC Public Document Room (PDR), to the extent possi)le, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for 4

i withholding the information from the public. I Dated at Atlanta, Georgia this 7th day of November 1996 l l

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