IR 05000324/1998004
| ML20236P390 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/10/1998 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Keenan J CAROLINA POWER & LIGHT CO. |
| References | |
| 50-324-98-04, 50-324-98-4, 50-325-98-04, 50-325-98-4, EA-98-182, NUDOCS 9807160293 | |
| Download: ML20236P390 (3) | |
Text
July 10, 1998
SUBJECT:
NRC INSPECTION REPORT N05. 50-325/98-04 AND 50-324/98-04
Dear Mr. Keenan:
This refers to the NRC inspection conducted February 9-13. March 9-12 and March 16-20. 1998. at Carolina Power and Light Company's (CP&L) Brunswick facility.
The results of the inspection were formally transmitted to Mr. C. Hinnant by letter dated April 16, 1998.
In that letter with the enclosed inspection report, four apparent violations were identified which were being considered for escalated enforcement.
The apparent violations related to three failures to perform resp #iTe time testing in accordance with Technical Specifications (TS) for certain groups of instruments and one failure to perform an adequate 10 CFR 50.39 evaluation.
In our letter CP&L was requested to respond to the apparent violations and circumstances surrounding them in writing, or request a predecisional enforcement conference.
CP&L responded to this request in a letter dated May 18. 1998.
CP&L's May 18. 1998 letter described an evaluation of the causes of the apparent violations, the corrective actions to prevent recurrence, and the understanding of the safety and regulatory significance.
In summary, the cause of the inadequate 10 CFR 50.59 evaluation was the failure to recognize that instrument response time testing was required by TS.
Therefore, changes in this area could not be implemented in accordance with 10 CFR 50.59.
CP&L indicated that the failures to conduct the testing at the appropriate times were a direct result of the inadequate 10 CFR 50.59 evaluation.
CP&L also indicated that the safety and regulatcry significance was minimal. since instrument response time testing was being performed using NRC accepted methodology and significant degradation would have been detected during other
/f/
calibration and surveillance testing activities.
'
Based on the information developed during the inspection. and our consideration of the information provided in CP&L's May 18 letter, the NRC has determined that a violation of 10 CFR 50.59 requirements occurred.
A detailed description of the circumstances surrounding the violation is described in the inspection report issued on April 16. 1998.
Our review of this issue revealed that the three apparent violations for failure to conduct adequate response time testing in accordance with TS were the direct result of the inadequate 10 CFR 50.59 evaluation.
_
9807160293 980710 PDR ADOCK 05000324 G
--
${0f
_ _ ___ - _
.
-
.
,
Normally, a violation for an inadequau 10 CFR 50.59 evaluation that results in a significant failure to follow TS would be classified at Severity Level III. However, in this case, the NRC has determined that this violation does not constitute a significant regulatory concern and therefore should be classified at Severity Level IV in accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions." NUREG-1600.
The bases for this determination included:
(1) CP&L was generally performing instrument response time testing of the affected systems (Reactor Protection System.
Primary and Secondary Containment Isolation System and Emergency Core Cooling System) in accordance with methodology that has been approved in other cases by the NRC (i.e.. BWR Owners Grou) Licensing Topical Report NED0-32291 which was approved as an acceptable methodology in an NRC Safety Evaluation Report issued on December 28, 1994): (2) the safety significance was low, since CP&L was conducting calibration and surveillance tests that would have detected degradation of the systems: (3) CP&L's methodology for testing was approved by the NRC in a subsequent TS amendment: (4) the inadequate 10 CFR 50.59 evaluation was an isolated case and not reflective of a programmatic breakdown in CP&L's evaluation 3rocess; and (5) there was no actual adverse impact on plant safety or opera]ility of the affected systems due to the testing methodology CP&L was performing.
We note that this last item was also a
]artial basis for NRC's grant of a Notice of Enforcement Discretion (NOED) on iarch 25.1997, when CP&L discovered the problem and requested the NOED.
The NRC acknowledges that CP&L identified the inadequate 10 CFR 50.59 evaluation in March 1997, and reported the issue to the NRC as required.
Additionally, the NRC finds CP&L's corrective actions, as documented in the May 18. 1998, letter and the Licensee Event Report acceptable. Accordingly, the NRC is dispositioning this non-repetitive. licensee identified and corrected violation as a Non-Cited Violation, consistent with Section VII.B.1 of the Enforcement Policy. Accordingly, no response to this correspondence is required.
-In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of this letter and CP&L's response, should you provide one, will be placed in the NRC Public Document Room (PDR).
Sincerely
.
original signed by JRJ for LAR Luis A. Reyes Regional Administrator Docket Nos. 50-325. 50-324 License Nos. DPR 71. DPR-62 cc: see page 3 w_
__
___
-
..
_
_
__
. _ _ _ _ _ _ _ _.
~
'
.
.
.
1 Distribution w/ encl:
J. Lieberman. OE B. Summers. OE (2 copies letterhead)
L. Plisco. RII A. Boland, RII M. Ernstes, RII D.' Trimble. NRR J. Coley. RII R. Baldwin. RII J. Lenahan. RII T. Reis. OE RI. RIII, RIV Enforcement Coordinators V. Nerses, NRR A. Kugler. NRR PUBLIC NRC Resident Inspector U. S. Nuclear Regulatory Commission 8470 River Road. SE Southport NC 28461
,
)
/
SEND TO PUBLI[ J0CUMENT ROOM?
YES
/
,
OFFICE RII:fik /
Ril:pRP, RIM
/RII:0RA RII:0RA Signature d
[
,
I I'
'
'
'
NAME JJa ud w 1 LWiscd abo arti CEvans JJbhnson DATE 1/ $ /18
/@
49S Q / h /98 1/ I /43 7/ IO
/98 I
COPY?
YES [lio )
YES IN0)
"YEM NO YES h
YES
[NO)
0FFICIAL RECORD C0bt4 ILE NAME HM980PEMF \\ 98182BRU. DI R\\ 98182RE1. F I N I
i