ML14188B706
| ML14188B706 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/01/1990 |
| From: | Lainas G Office of Nuclear Reactor Regulation |
| To: | Eury L Carolina Power & Light Co |
| References | |
| TAC-72969 NUDOCS 9006070321 | |
| Download: ML14188B706 (4) | |
Text
.4 UNITED STATES NUCLEAR REGULATORY COMMISSION 3E WASHINGTON, D. C. 20555 June 1, 1990 Docket No. 50-261 Mr. Lynn W. Eury Executive Vice President Power Supply Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602
Dear Mr. Eury:
SUBJECT:
SINGLE FAILURE CRITERION, ELECTRICAL SYSTEMS - H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 (TAC NO. 72969)
By letters dated April 19, May 19, and June 14, 1989, you responded to the NRC staff's request, under 10 CFR 50.54 (f), concerning your actions, taken or planned, regarding single electrical failure evaluation for ECCS and other safety systems. This subject was further discussed with the staff during a meeting on April 19, 1990. The purpose of this letter is to request your documentation of commitments and actions that would be responsive to the staff's request under 10 CFR 50.54(f).
By letters dated April 19 and May 19, 1989, you have committed to reevaluate the ECCS to assure that the acceptance criteria of 10 CFR 50.46, along with the single failure criterion of Appendix K, can be met. Through your discussions with the staff, we understand that this effort is in progress as scheduled and should be completed prior to the end of the refueling outage 13.
Within 60 days following the end of the outage, you are requested to submit the results of your evaluation to provide assurance that the single failure criterion of Appendix K is being met.
You were also requested to identify and correct single electrical failure vulnerabilities per 10 CFR Part 50, Appendix A, General Design Criteria (GDC) for safety systems other than the ECCS. In response to that request, by letter dated June 14, 1989 and during the meeting on April 19, 1990, you stated that you have embarked on two programs, the Design Basis Documentation (DBD) program and the overall plant-based Level I Probabilistic Risk Assessment (PRA).
Those programs are not designed to ensure literal compliance with the Appendix A single failure criterion for electrical systems. However, you stated that you "feel strongly that the programs...
will assure that the plant meets the basic intent of the GDC, which is to ensure...
that the plant can be operated without undue risk to the health and the safety of the public."
In essence, your reference to "without undue risk" represents meeting the statutory require ments of Section 182 of the Atomic Energy Act for "adequate protection of the health and safety of the public," 42 USC 2232. The staff agrees with you in that the GDC are considered to be a codification of the requirements existing at the time Robinson was licensed (e.g., Section 182 of the Act) and could be used as a benchmark to assess the safety of the facility. However, deviations from the GDC must be justified on the basis that deviations provide an equivalent
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Mr. Lynn June 1, 1990 degree of safety, whether or not exemptions from the GDC are required. There fore, you are requested to commit to demonstrate that the plant can meet "an equivalent degree of safety" as afforded by meeting the GDC.
During the meeting on April 19, 1.990, you discussed the DBD and the PRA programs. It is still not clear how these programs will demonstrate "an equivalent degree of safety."
For example, you stated that it was not the function of the DBD program to identify electrical single failure vulnerabilities. However, without such identification (i.e., without first identifying the deviations from the GDC), it is unclear to us how the demonstration of "an equivalent degree of safety" can be accomplished.
Therefore, you are requested to submit a description of your plan clearly identifying how the DBD and PRA program will demonstrate equivalence, including sufficient detail on criteria and methodology. The plan description, including its schedule, should be submitted to us within 60 days of the receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P. L.96-511.
Sincerely, Herbert Berkow/for Gus C. Lainas, Assistant Director for Region II Reactors Division of Reactor Projects -1/11 Office of Nuclear Reactor Regulation cc:
See next page DISTRIBUTION See attached page OFC
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Mr. L. W. Eury H. B. Robinson Steam Electric Carolina Power & Light Company Plant, Unit No. 2 cc:
Mr. R. E. Jones, General Counsel Mr. Dayne H. Brown, Director Carolina Power & Light Company Department of Environmental, P. 0. Box 1551 Health and Natural Resources Raleigh, North Carolina 27602 Division of Radiation Protection P. 0. Box 27687 Raleigh, North Carolina 27611-7687 Mr. H. A. Cole Special Deputy Attorney General Mr. Robert P. Gruber State of North Carolina Executive Director P. 0. Box 629 Public Staff - NCUC Raleigh, North Carolina 27602 P. 0. Box 29520 Raleigh, North Carolina 27626-0520 U.S. Nuclear Regulatory Commission Mr. C. R. Dietz Resident Inspector's Office Manager, Robinson Nuclear Project H. B. Robinson Steam Electric Plant Department Route 5, Box 413 H. B. Robinson Steam Electric Plant Hartsville, South Carolina 29550 P. 0. Box 790 Hartsville, South Carolina 29550 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Mr. Heyward G. Shealy, Chief 101 Marietta Street Bureau of Radiological Health Suite 2900 South Carolina Department of Health Atlanta, Georgia 30323 and Environmental Control 2600 Bull Street Mr. R. Morgan Columbia, South Carolina 29201 General Manager H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, South Carolina 29550
TS DISTRIBUTION Docket File NRC PDR Local PDR J. Partlow 12-G-18 A. Thadani 12-G-18 S. Varga 14-E-4 G. Lainas 14-H-3 E. Adensam 14-B-20 P. Anderson 14-B-20 R. Lo 14-B-20 B. Mozafari F. Rosa L. Reyes RII D. Verrelli RII OGC 15-B-18 E. Jordan MNBB-3302 ACRS (10)
P-315 Robinson File