ML18010B066
| ML18010B066 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/26/1993 |
| From: | VAUGHN G E 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
I(