ML18009A317

Responds to NRC 891108 Ltr Re Violations Noted in Insp Rept 50-400/89-21.Corrective Actions:Incident Reviewed by Both Plant & Nuclear Engineering Dept Personnel to Avoid Future Miscommunication

ML18009A317
Person / Time
Site:	Harris
Issue date:	12/21/1989
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-694 NUDOCS 9001020244
Download: ML18009A317 (6)

Text

P]F>IIIBUTIO'N Dg/Ohigi'QTl04 SYSTEM ACCESSZON NBR:9001020244 DOC.DATE:

~ 89/12/21 NOTARIZED: NO DOCKET "ACZL:50-400 Shearon Harris Nuclear Powe Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFZLZA ZON RICHEY i R. B.~

~ Carolina Power ~ Light Co. ~

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 891108 ltr re violations noted in Znsp Rept 50-400/89-21.Corrective actions noted.

DISTRIBUTION CODE: ZE01D COPIES RECEIVED:LTR ENCL SIZE:

.ZTLE: General (50 Dkt)-Znsp Rept/Notice of Violation Response NOTES:Application for permit renewal filed. 05000400 EC Z PI E'NT COPIES RECIPIENT COPIES ZD CODE/NAMF L TR ENCL ZD CODE/NAME LTTR ENCL PD2-1 PD 1 BECKER,D 1 1

NTERNAL: ACRS AEOD A OD/DEZZB AEOD/TPAD D"DRO NRR SHANKMAN,S NRR/DLPQ/LPEB10 NRR/DOEA DZR 11 NRR/DREP/PEPB9D NRR/DREP/PRPB1 NRR/DRIS/DIR NRR/DST/DIR 8E2 NRR/PMAS/ZLRB12 NUDOCS-ABSTRACT 0" L:" %N J OGC/HDS1 02 RES MORZSSEAU,D 2 FILE Ol EfiTERNAL: L~DR NRC PDR NS1C NOTE 'ZO ALL "RIDS" RECIPEZPIS' PLEASE HELP US ZO REDOCE HASTE! COMI'ACZ 'ZHE DOCUMENI'GHI'ROL DESK RDCN Pl-37 (KCI'. 20079) XO XZZ? GRATE YOUR NAME HtCN DISTRIBUTION LISTS FOR DOCEGWZS YOU DON'T NEEDt TOTAL NUMBER OF COPZES REQUiRED: LTTR 26 ENCL 26

l Carolina Power & Ught Company P. O. Box 165 ~ New Hill, N. C. 27562 HARRIS NUCLEAR PROJECT P.O. Box 165 R. a. RCHEY Manager New Hill, North Carolina 27562 Hanla Nuclear Pnllect DEC 2 1 1989 Letter Number: HO-890171 (0)

Document Control Desk NRC-694 United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:

In reference to your letter of November 8, 1989, referring to I.E. Report RII: 50-400/89-21, the attached is Carolina Power, and Light Company's reply to the violation identified in Enclosure 1.

It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.

Via telephone conversation between Mr, Michael Wallace (CPhL), Mr. Jeff Tedrow and Bob Carrol of your staff on December 7, 1989 an extension was granted to CPBL for responding to the violation. The reason for the extension was due to a delay in the Harris Plants receipt of the Notice of Violation.

Thank you for your consideration in this matter.

R. B. Ricney, Man ger Harris Nuclear P ject MGW:dgr Attacnment cc'Mr. R. A. Becker (NRC)

Mr. S. D. Ebneter (NRC RII)

Mr. J. E. Tedrow (NRC SHNPP)

MEM/HO. B901710/1/OS1 9001020244 891221 PDR ADQCK 05000400 8 PNU

Attachment to CP6L Letter of Res onse to NRC I. E. Re ort Rll: 50-400/89-21 Re orted Violation.'0 CFR Part 50, Appendix B, Criterion III, Design Control, requires that measures be established for the selection and review for suitability of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems and components.

Contrary to the above, commercial grade ITE Molded Case Circuit Breakers were installed in safety-related electrical systems and the review for suitability of equipment by the CP6L Engineering Department was inadequate. The breakers were physically changed by the manufacturer (i.e., instantaneous trip and voltage rating) and the seismic qualifications of the breakers were not verified prior to installation in safety-related applications. Further, the modified breakers were not fully qualified by testing in that all of the required critical characteristic tests (i.e., a dielectric test between the line and load terminals with the breaker open, a full load starting current test, contact resistance measurement with the breaker closed, or testing with the breaker properly oriented) were not considered or performed.

This is a Severity Level IV Violation (Supplement I) ~

Denial or Admission and Reason for Violation'.

The violation is admitted.

Commercial grade ITE molded case circuit breakers were installed in safety-related equipment at the Harris Nuclear Plant (HNP) without an adequate review. HNP personnel had identified a change to the subject breakers and requested an engineering evaluation of the change via Plant Change Request (PCR) 4007. The Nuclear Engineering Department (NED) understood the scope of PCR-4007 to be limited to evaluating the acceptability of the changes in the time current curves in regards to the electrical coordination/protection studies. PCR 4007 did not evaluate the seismic qualification of the subject breakers.

Further, the dedication process for the subject breakers did not include testing of critical characteristics. During the time frame the subject breakers were received at HNP, testing was not being performed of breakers received based on several breaker manufacturers indicating that initial testing was detrimental to the breaker.

Corrective Ste s Taken and Results Achieved:

A field revision to PCR-4007 has been initiated and is currently being worked to evaluate the acceptability of using the subject commercial grade breakers in safety-related applications. At present the breakers installed in safety-related applications are acceptable from an electrical standpoint and are considered to be seismically qualifiable based on the Seismic MEM/H0-8901710/2/OS1

Qualification Utility Group (SQUG) curves which envelope this application.

However, additional seismic testing (through Wyle Test Labs) and evaluation of test results will be performed to provide documentation of seismic qualification. This effort will be completed by January 31, 1990.

The subject breakers installed in safety-related application have been tested per procedure CM-E0010, 480 VAC Molded Case Circuit Breaker Test or equivalent surveillancelperiodic test procedures with acceptable results achieved. Tests include smooth breaker operation, breaker continuity, megger measurement, thermal trip test and instantaneous trip test.

Corrective Ste s Taken to Avoid Further Violations'.

This incident has been reviewed by both plant and NED personnel to avoid future miscommunication as to the scope of PCRs.

Molded case circuit breakers purchased for safety related applications are purchased commercial grade and are tested for critical characteristics upon receipt per procedure CM-E0010. This requirement has been added to the receipt inspection instructions. Test data sheets are kept with each breaker placed in stock.

Date When Full Com liance Will Be Achieved:

Full compliance is expected by January 31, 1990.

MEM/HO-8901710/3/Osl

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