ML18005A251
| ML18005A251 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/19/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML18005A252 | List: |
| References | |
| EA-87-201, NUDOCS 8801250454 | |
| Download: ML18005A251 (6) | |
See also: IR 05000400/1987034
Text
0
ACCELZRAYZD
DESI'RIBUTION
DEMONSTRATION
SYSTEM
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 8801250454
DOC. DATE: 88/01/19
NOTARIZED: NO
FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina
AUTH.NAME
AUTHOR AFFILIATION
GRACE,J.N.
Region 2, Ofc of the Director
RECIP.NAME
. RECIPIENT AFFILIATION
UTLEY,E.E.
Carolina Power
& Light Co.
DOCKET
N
05000400
05000400+
SUBJECT: Discusses
Insp Rept 50-400/87-34
on 870820-0924
& forwards
DISTRIBUTION 'CODE: IEOID
COPIES
RECEIVED:LTR ENCL J
SIZE: ~+&
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:Application for permit renewal filed.
RECIPIENT
ID CODE/NAME
PD2-1
PD,
INTERNAL: AEOD
NRR MORISSEAU i D
NRR/DOEA DIR
NRR/DREP/RPB
NRR/PMAS/ILRB
OGC/HDS1
RES/DRPS
DIR
ERNAL: LPDR
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
BUCKLEY,B
DEDRO
NRR/DLPQ/PEB
NRR/DREP/EPB
NRR/DRIS DIR
RMANiJ
REG FILE
GN2
FILE
01
NRC PDR
COPIES
LTTR ENCL
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
A
A
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
21
ENCL
21
JAN19 $88
Docket No. 50-400
License
No.
EA 87-201
Carolina
Power
and Light Company
ATTN:
Mr. E.
E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P. 0.
Box
1551
Raleigh,
NC
27602
Gentlemen:
SUBJECT:
(NRC
INSPECTION
REPORT
NO. 50-400/87-34)
This refers
to the Nuclear Regulatory
Commission
(NRC) inspection
conducted
by
G.
F. Maxwell
on August 20 - September
24,
1987.
The inspection
included
a
review of selected activities authorized for your Shearon
Harris facility.
The
report documenting this inspection
was sent to you by letter dated
October
14,
1987.
The
NRC concerns relative to these findings were discussed
in an Enforce-
ment Conference
held on October 21,
1987.
Documentation of this conference
was
sent to you by letter dated
November 4,
1987.
The violation described
in the enclosed
Notice of Violation involved a failure
to take appropriate
action to maintain containment isolation capability for the
"A" steam
generator
blowdown piping
system,
containment
M-51,
during
the period
August
13 to September
13,
1987,
as required
by Technical
Specifications.
Based
on the
Enforcement
Conference
held
on October 21,
1987
and your subsequent
letter of October 29,
1987,
we understand
that your inter-
pretation of this specification
assumed
that the
ACTION statement
for a *two
valve system
(open),
GDC 55 and 56,
was "mirrored" for the single valve case.
Specifically for ACTION item "b", which required isolating the penetration
by
use of at least
one deactivated
automatic
valve,
you
assumed
that if the
OPERABLE isolation valve in the
two valve
system could
be used to meet this
ACTION item, then the closed
system,
acting
as
an
OPERABLE isolation valve in a
single valve
system,
could also
be
used.
In this particular case,
you used
this interpretation
to continue
operation
when
containment
isolation valve
1BD-11 failed open,
in that the closed
system
was already,
by description,
"closed" and thus
no valve operation
was necessary
to meet
ACTION item "b".
We find your interpretation
incor rect
and unreasonable.
It is our position
that in all instances,
ACTION items in Technical Specifications
require,
as the
word implies, "action" of some sort.
In your interpretation,
no action whatso-
ever
was required,
when in fact, the
ACTION item requires
a valve shutting
and
deactivation action.
While we do not consider that your interpretation repre-
sents
a flagrant disregard for the intent of this Technical Specification,
you
should
have recognized
that your "no action" interpretation
was incorrect.
As
a
minimum,
we would
have
expected
your staff to contact
the
NRC Resident
8801250454
880119
- DOCK 05000400
A
.
.
agog
Carolina
Power and Light Company
2
JAN 2 9 1988
Inspector for Operations
to obtain clarification assistance
when they recognized
there
was
a Technical
Specification
interpretation
problem.
Instead of this
course of action which was
immediately available to your staff, they chose
to
debate
the problem's solution.
This Technical Specification violation was considered for issuance
as
a Severity
Level III. We recognize that although valve
1BD-11 was
open during this. time-
frame and would not isolate
when required,
two valves inside containment,
180-1
and
not classified
as
containment
isolation valves,
are
designed
to
isolate
on
a safety injection signal.
Because
the safety significance of this
event is mitigated
by the auto-isolation feature of the two inside-containment
valves,
the violation described
in the enclosed
Notice has
been classified
as
a
Severity Level
IV Violation.
You are required to respond
to this letter
and should follow the instructions
specified
in the
enclosed
Notice
when
preparing
your response.
In your
response,
you should
document
the specific actions
taken
and
any additional
actions
you plan to prevent recurrence.
After reviewing your response
to this
Notice, including your proposed
corrective
actions
and the results of future
inspections,
the
NRC will determine
whether further
NRC enforcement
action is
necessary
to ensure
compliance with
NRC regulatory requirements.
In accordance
with Section
2.790 of NRC's "Rules of Practice,"
Part 2, Title 10,
Code of Federal
Regulations,
a copy of this letter
and its enclosure will be
placed in the
NRC Public Document
Room.
The responses
directed
by this letter and its enclosure
are not subject to the
clearance
procedures
of the Office of Management
and Budget
as required
by the
Paperwork
Reduction Act of 1980,
PL 96-511.
Should you have
any questions
concerning this letter, please
contact us.
Sincerely,
Enclosure:
J.
Ne son
Grace
Regional Administrator
cc w/encl:
R. A. Watson,
Vice President
Harris Nuclear Project
0. L. Tibbitts, Director of Regulatory
Compliance
J.
L. Willis, Plant General
Manager
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