ML18010B066

Responds to NRC 930225 Ltr Re Violations Noted in Insp Rept 50-400/93-03.Corrective Actions:Mgt & Organizational Changes Will Provide Further Enhancement to EP Program by Shifting Responsibility for Conducting Drills & Exercises

ML18010B066
Person / Time
Site:	Harris
Issue date:	03/26/1993
From:	Vaughn G CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-807 HO-930070, NUDOCS 9303290224
Download: ML18010B066 (11)

See also: IR 05000400/1993003

Text

ACCELERATED

DOCUMENT DISTRIBUTION

SYSTEM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ACCESSION'BR:9303290224

DOC.DATE: 93/03/26 NOTARIZED:

NO ACIL:50-400

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

AUGHNiG.E.

Carolina Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET N 05000400 SUBJECT: Responds to NRC 930225 ltr re violations

noted in insp rept 50-400/93-03.'Corrective

actions:mgt

&organizational

changes will provide further enhancement

to EP program by shifting responsibility

for conducting

drills&exercises.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES:Application

for permit renewal filed.05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS AEOD/DSP/TPAB

DEDRO NRR/DRCH/HHFBPT

NRR/DRSS/PEPB

NRR/PMAS/ILPB2

REG FIL 02 RGN2'FILE 01 EXTERNAL: EG&G/BRYCE,J.H.

NSIC 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 RECIPIENT ID CODE/NAME LE,N AEOD/DEIB AEOD/TTC NRR/DORS/OEAB

NRR/DRIL/RPEB

NRR/PMAS/ILPB1

NUDOCS-ABSTRACT

OGC/HDS1 RES MORISSEAU,D

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 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US fO REDUCE WASTE!CONTACT TIIE DOCUMEN'f CONTROL D)>V, ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISmIDU'f ION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 23

'

t Carolina Power&Light Company P.O.Box 165~New Hill, NC 27562 G.E.VAUGHN Vice President Harris Nuclear Plant MAR 2 6 199'etter Number: HO-930070 Document Control Desk United States Nuclear Regulatory

Commission

Washington, DC 20555 NRC-807 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400 LICENSE NO.NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In refere nce to your letter of February 25, 1993, referring to NRC Inspection

Report RII: 50-400/93-03, the attached is Carolina Power and Light Company's reply to the notice of violation identified

in Enclosure 1.Thank you for your consideration

in this matter.Very truly yours, Vice President Harris Nuclear Plant MGW:kls Attachment

cc: Mr.S.D.Ebneter (NRC-RII)Mr.N.B.Le (NRC-NRR)Mr.J.E.Tedrow (NRC-SHNPP)

9303290224

93032b PDR ADQCK 05000400 8 PDR MEM/HO-930070/1/Osl (t(t

Attachment

to NRC-807 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50-400/93-03

VIOLATION 400 93-03-01 Re orted Violation:

10 CFR 50.54(q)states that a licensee authorized

to possess and operate a nuclear power reactor shall follow and maintain in effect an emergency plan which meets the standards in 10 CFR 50.47(b)and the requirements

of appendix E to 10 CFR Part 50.10 CFR 50.47(b)(8)

requires that adequate emergency facilities

and equipment to support the emergency response are provided and maintained.

Section3..1 ofthe Shearon Harris Emergency Plan, which implements

10 CFR 50.47(b)(8), states that adequate emergency facilities, communication, and equipment to support emergency response are provided and maintained.

Section 3.5.3.b of the Shearon Harris Emergency Plan identifies

Emergency Response Facility Information

System (ERFIS)consoles, capable of displaying

plant data, SPDS, and RMS, as Emergency Operations

Facility equipment to be maintained.

PEP-402,"Maintaining

Readiness of Emergency Facilities, identifies

Portable Radios and Base Stations as emergency equipment.

Contrary to the above, two examples of inadequately

maintained

equipment were identified:

1.=When tested by the inspector, two of the six hand-held mobile radios maintained

in the Operational

Support Center (OSC)kits failed to transmit.2.When an operational

demonstration

was requested by the inspector, Emergency Operations

Facility (EOF)ERFIS terminals 1, 2, and 3 did not operate.This is a Severity Level IV violation (Supplement

VIII).Denial or Admission:

The violation is denied.(Example 1)OSC emergency response personnel are taught to check equipment such as radios to ensure proper operation prior to leaving the OSC on a mission.It is true that on the date of the NRC inspectors

visit and upon examination

of one of the three'SC emergency supply kits, two of the six hand-held-.radios failed to transmit due to deficient batteries.

However, there were spare batteries available in the kit for use in the radios.This was demonstrated

at the time of the inspection.

MEM/HO-930070/2/OS1

Attachment

to NRC-807 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50-400/93-03

Since radio operability

checks are normal practice and spare batteries were available, CP&L contends that the radios were available for use at the time of inspection.

The condition noted by the inspector is not considered

a violation of the Emergency Plan or implementing

procedure (PEP-402).

The cause of the two batteries not to function properly was due to memory lock on the batteries.

In order to alleviate the memory lock problem a battery manager is being purchased and batteries for the OSC radios will be rotated through the battery manager.(Example 2)It is true that when an operational

demonstration

was requested by the inspector on January 26, 1993, the EOF ERFIS terminals 1, 2, and 3 did not operate.First, it should be made clear that alternate means of transmitting

plant operating data to the Technical Support Center (TSC)and EOF is available.

Secondly, the problem that ultimately

would cause the non-operational

state noted by the inspector had been recognized

on January 21, 1993, and a work ticket was written to correct the switcher problem.On January 25, 1993, an upgrade to enhance the reliability

of our ERFIS system was initiated.

The EOF equipment was operating properly on January 22 1993, and January 25, 1993, when checked by a member of the Harris Emergency Preparedness (EP)staff.On the morning of January 26, 1993, as part of the ERFIS upgrade, the switchers were activated and since the switcher for the EOF ERFIS equipment was not functioning

properly, the EOF ERFIS equipment went off line.This was discovered

at about 4 p.m.on January 26, 1993, when the demonstration

was requested by the inspector in the EOF.The Specialist

contacted by phone to place the EOF ERFIS equipment on line was not aware of the switcher problem.From his look at the equipment he felt the EOF equipment should be on line.The next morning the technician

that normally works with the EOF equipment became aware of the problem, he changed switchers and had the EOF equipment back on line within 30 minutes on January 27, 1993.The ERFIS computer is a very complex computer system with numerous remote devices subject to various perturbations

which can trip various components

off line.However, we have the ability to return these components

very rapidly to an operational

status by getting the proper qualified technician

in the Computer Control Room to accomplish

the proper line up.The technicians

are trained as part of the Emergency Response Organization

and during emergencies

or exercises are called in to perform any required adjustments

in order to keep ERFIS functional.

CP&L does not consider this to be a violation in that the problem had been self-identified

and the ability to rapidly place the equipment back on line by a qualified technician

is available and was demonstrated.

The ERFIS upgrade is an ongoing major proj ect to improve the operation and reliability

of the ERFIS system.This fact has been noted as one of the strengths in the EP Program in the past.Further, the upgrade of the ERFIS will greatly enhance the system's entire capability.

The particular

switcher problems have been repaired and an upgrade with new model, more reliable switchers had been identified

as part of the ERFIS upgrade.The replacement

of these switchers is to be accomplished

in 1993.MEM/HO-930070/3/OS1

Attachment

to NRC-807 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50-400/93-03

VIOLATION 400 93-03-03 Re orted Violation:

10 CFR 50.54(q)states that a licensee authorized

to possess and operate a nuclear power reactor shall follow and maintain in effect an emergency plan which meets the standards in 10 CFR 50.47(b)and the requirements

of Appendix E to 10 CFR Part 50.10 CFR 50, Appendix E.IV.D.2 states that signs or other measures shall also be used to disseminate

to any transient population

within the plume exposure pathway Emergency Planning Zone (EPZ)appropriate

information

that would be helpful if an accident occurs.Section 5.2.5 of the Shearon Harris Emergency Plan states that adhesive decals are located at public telephone booths in the 10-mile EPZ to inform transients

that they are in an emergency warning zone and what immediate actions to take should they hear the sirens.Contrary to the above, four out of eight telephone booths surveyed by the inspector did not display the adhesive decals.This is a Severity Level V violation (Supplement

VIII).Denial or Admission:

While the above statement is true, CPGL requests that the NRC withdraw the violation as allowed by 10CFR2 Appendix C VII B[1].The basis for this request is (a)this condition was not one which could be expected to have been prevented by the licensee's

corrective

action for a previous violation, (b)corrective

action was initiated prior to the end of the inspection

to survey public phone booths within the 10-mile EPZ and ensure the decals were in place and (c)this was not a willful violation.

The public phone booth decals serve only as an enhancement

to other more effective and logical means of notifying the transient population

as to the meaning of sirens and what actions to take.More realistic warning to transients

would naturally come from their asking someone within the 10 mile EPZ what the sirens indicate.The residents and businesses

within the 10 mile EPZ are furnished with an Annual Emergency Preparedness

Calendar with all the information

concerning

sirens, possible evacuations

and turning to Emergency Broadcast Frequencies

on Radio or TV.The other most logical means of providing the information

to transients

is the Emergency Broadcast System which would carry information

concerning

the emergency or drill.In addition to fixed sirens sounding in the event of a real emergency," the vehicle routes inside the 10 mile EPZ will have emergency vehicles with flashing lights, sirens and broadcast capabilities

doing route alerting which would alert the permanent and transient populations.

Efforts were underway prior to the inspection

to enhance the entire program of notification

of transients.

While CP&L has had a contract in force with the areas major telephone company to ensure that the decal information

is placed in MEM/HO-930070/4/OS1

,~

I Attachment

to NRC-807 g'REPLY TO A NOTICE OF VIOLATION NRC INSPECTION

REPORT NO.50-400/93-03

all of their public telephones

within the 10 mile EPZ, we recognize the difficulty

in ensuring decal placement and preventing

removal of the decals by members of the public.CP&L is currently evaluating

the basis for this commitment.

Because of the marginal value of decals and the availability

of more effective means to notify the transient population

during an emergency, CP&L intends to pursue a change to'the Emergency Plan removing the commitment

to have the adhesive decals located in public telephone booths throughout

the 10 mile EPZ.In conclusion, the Shearon Harris Nuclear Plant has an effective EP Program.This is evidenced by the successful

annual graded exercises conducted without NRC identified

deficiencies

or weaknesses

for the past several years.Recently announced management

and organizational

changes will provide further enhancement

to the EP Program by shifting responsibility

for conducting

drills and exercises, including scenario development, from the EP Organization

to the Harris Training Section.This move will allow the EP Organization

to improve their focus on administration

responsibilities

and program compliance.

MEM/HO-930070/5/OS1

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