ML18012A838
| ML18012A838 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/22/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Robinson W CAROLINA POWER & LIGHT CO. |
| References | |
| 50-400-97-06, 50-400-97-6, EA-97-288, NUDOCS 9707310089 | |
| Download: ML18012A838 (9) | |
See also: IR 05000400/1997006
Text
CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9707310089
DOC.DATE: 97/07/22
NOTARIZED: NO
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CIL:50-400 Shearon Harris Nuclear
Power Plant, Unit 1, Carolina
UTH.NAME
AUTHOR AFFILIATION
REYES,L.A.
,
Region
2 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
ROBINSON,W.R.
Carolina
Power
& Light Co.
DOCKET
05000400
SUBJECT:
Discusses
insp rept 50-400/97-06
on 970621.Violation noted:
failure of FSAR .to accurately reflect as-built plant
configuration
& failure to perform evaluation in accordance
w/10CFR50.59.Enforcement
discretion warranted.No
NOV issued.
DZSTRZBUTZON CODE:
ZEOZT
COZlZES RECEZVED:LTRj ENCL 0 SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:Application for permit renewal filed.
05000400
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RECIPIENT
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PD2-1
INTERNAL: ACRS
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FILE ..01
EXTERNAL: LITCO BRYCE,J
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NRC PDR
COPIES
LTTR ENCL
2
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RECIPIENT
ID CODE/NAME
ROONEYgV
AEOD/SPD/RAB
DEDRO
NRR/DISP/PIPB
NRR/DRPM/PECB
NUDOCS-ABSTRACT
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ENCL
July 22, 1997
EA 97-288
Carolina Power
& Light Company
ATTN:
Hr .
W. R. Robinson
Vice President
- Harris Plant
Shearon Harris Nuclear Power Plant
P. 0. Box 165, Hail Code:
Zone
1
New Hill, NC
27562-0165
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION
Dear
Hr . Robinson:
On June 21,
1997, the
NRC completed
an inspection at Carolina
Power
& Light
Company's
(CP&L) Har ris facility.
The results of that inspection are
documented in NRC Inspection Report 50-400/97-06.
During the inspection,
the
NRC examined the facts
and circumstances
surrounding
CP&L's identification of a design deficiency associated
with
(EDG) protection circuitry.
Specifically, during
a
review associated
with NRC Generic Letter 96-01, Testing of Safety Related
Logic Circuits, your staff determined that during periodic
EDG load testing
situations coincident with a Loss of Offsite Power
(LOOP),
an overcurrent
relay (51V) would not have sensed
an over current condition and tripped the
feeder breaker.
As a result of this condition, if a
LOOP occurred during
testing, the 51V relay would not have actuated
and the associated
emergency
sequencer
would not have recognized the
LOOP condition and sequenced
the
safety loads
as required.
The condition was reported to the
NRC on
. December
4.
1996,
and Licensee
Event Report
No.96-023 was submitted
on
December
16,
1996,
and supplemented
on Hay 29,
1997 and June 6, 1997,
describing the outside of design basis condition.
On April 18,
1997,
a
proposed
EDG protection circuitry modification was submitted to the
NRC in
accordance
with 10 CFR 50.59(c)-and
On Hay 8, 1997, the
NRC
issued
Amendment
No. 72 to the Harris 'license approving the modification.
Based
on the information developed during the inspection,
the
NRC has
determined that
a violation of NRC requirements
occurred.
Bpeci,fically, since
original plant oper ation, the
EDG protection logic was not designed
as
described in Sections 7.3.1;5.1.and "8.3.1.1.2.14.g of the Harris Final Safety
Analysis Report
(FSAR).
No evaluation
was performed pursuant to 10 CFR 50.59
to determine if the actual configuration constituted .an Unreviewed Safety
Question
(USQ); although after your recent discovery of the condition you did
confirm that
a
USQ existed.
The failure of the
FSAR to accurately reflect the
as-built plant configuration and-the =Vailur e to perform an evaluation in
accordance
with 10 CFR 50.59 constitutes
a violation of regulatory
requirements.
t'l $ lt
9707M0089 970722
ADOCK 05000400
8
IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII
CPSL
In accordance
with the "General
Statement of Policy and Procedures
for
Enforcement Actions" (Enforcement Policy),
NUREG-1600, this violation normally
would be categorized
as
a Severity Level III violation.
However,
as provided
in Section VII.B;3 of the Enforcement Policy, the
NRC may refrain from issuing
a Notice of Violation (Notice)
and proposing
a civil penalty for a Severity
Level III violation which involves
a past problem,
such
as
an old engineering,
design,
or installation deficiency, provided that certain criteria are met.
After review of this violation and in consultation with the Director, Office
of Enforcement,
the
NRC has concluded that while a violation did occur,
enforcement discretion is warranted
and issuance of a Notice is not
appropriate in this case.
The speciAc bases f'r the decision to exercise
(1) you identified the design discrepancy while
consulting the
FSAR during Generic Letter 96-01 activities;
(2) the issue
was
appropriately reported in accordance
with 10 CFR 50.72 and 50.73;
(3) prompt
actions were taken to declare the
whenever they were
paralleled with the offsite power grid during testing;
(4) design
change
options were thoroughly pursued;
(4) the design
change
was submitted to
NRC in
accordance with 10 CFR 50.59(c)
and 50.90;
(5) the installation and testing of
the modification to the
EDG circuitry were completed
on Hay 26,
1997;
and
(6) the design discrepancy
was not likely to be identified by routine licensee
efforts.
In addition,
based
on NRC's assessment
of the scope
and thoroughness
of your on-going
FSAR review program, it is possible that this would have been
identified regardless
of the Generic Letter review.
This letter closes the apparent violation involving the 51V relay design
.
deficiency identified in the above referenced
inspection report.
No formal
response
regarding this issue is required.
In accordance
with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter will be placed in the
NRC Public Document
Room (PDR).
Sincerely,
Docket No.
50-400
License
No. NPF-63
cc:
(See
page 3)
( Original signed by L. Reyes
)
Luis A. Reyes
Regional Administrator
. CP&L
CC:
D. B. Alexander
. Hanager
Performance
Evaluation
and
Regulatory Affairs
OHS7
Carolina
Power
& Light Company
412 S. Wilmington Street
Raleigh,
NC
27601
J.,W.
Donahue
Director of Site Operations
Carolina
Power
& Light Company
S. Harris Nuclear. Power Plant
P. 0. Box 165,
HC:
Zone
1
New Hill, NC
27562-0165
Bo Clark "-
Plant General
Hanager
- Harris Plant
Carolina
Power
& Light Company
Shearon Harris Nuclear
Power Plant
P. 0. Box 165-
New Hill, NC
27562-0165
D. B. Alexander,
Supervisor
Licensing/Regulatory
Programs
Carolina
Power
& Light Company---
Shear on Harris Nuclear.:Power -Plant-
P. 0. Box 165, Hail Zone 1-
New Hill, NC
27562-0165
W. D. Johnson,
Vice President
and Senior Counsel
Carolina
Power
& Light Co;.
P. 0. Box 1551
Raleigh,
NC
27602
Hel Fry, Acting Director
Div. of Radiation Protection
N. C. Dept. of Environment,
Health
& Natural
Resources
3825 Barrett Drive
Raleigh,
NC
27609-7721
Karen E.
Long
Assistant Attorney General
State of North Carolina
P. 0. Box 629
Raleigh,
NC
27602
(cc cont'd
- See
page 4)
P,
l
CPSL
(cc cont'd)
Public Service Commission
State of South Carolina
P. 0.
Box 11649
Columbia,
SC
29211
Chairman of the North Carolina
Utilities Commission
P. 0. Box 29510
Raleigh,
NC
27626-0510
Rober t P. Gruber
Executive Director
Public Staff NCUC
P. 0. Box 29520
Raleigh,
NC
27626
Stewart
Adcock, Chairman
Board of County Commissioners
of Wake County
P. 0. Box 550
.
Raleigh,
NC
27602
-
- ~ Hargaret Bryant Pollard,=- Chairman
Board of County Commissioners
of Chatham County
P. 0. Box 87
Pittsboro,
NC
27312
Distribution:
J.
Lieberman,
OE.EA (BSummers)(2)
H. Shymlock, RII
B. Uryc, RII
J. Coley, RII
R. Baldwin, RII
J.
Lenahan,
RII
W. Rankin, RII
D. Thompson, RII
V. Rooney,
PUBLIC
(Distribution cont'd
- See
a e 5)
~
~
.itic .
$
~
CPSL
Distribution cont'd:,
NRC Resident
Inspector
U. S. Nuclear Regulatory Commission
5421 Shearon
Har ns
Road
New Hill, NC
- 27562-9998
=-
SIGHATURE
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