ML18011A683
| ML18011A683 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/17/1994 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Robinson W CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML18011A684 | List: |
| References | |
| EA-94-204, GL-89-13, NUDOCS 9411290226 | |
| Download: ML18011A683 (7) | |
See also: IR 05000400/1994021
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.. SUITE 2900
ATLANTA.GEORGIA 303234199
November 17, 1994
EA 94-204
Carolina
Power
and Light Company
ATTN:
Hr.
W.
R.
Robinson
Vice President
Shearon
Harris Nuclear
Power Plant
. P.
O.
Box 165
Hail Code:
Zone
1
New Hill, NC
27562-0165
SUBJECT:
(NRC
INSPECTION
REPORT
NO. 50-400/94-21)
Dear Mr. Robinson:
This refers to the inspection
conducted
by J.
Tedrow of this office on
September
3 - 28,
1994.
The inspection
included
(1)
a review of a longstanding
deficiency which resulted
in the failure of the emergency
(ESW)
system to meet single failure cri'teria,
and
(2) inaccurate
information provided
to the
NRC in response
The
ESW system deficiency was
reported in Licensee
Event Report 400/94-003
in accordance
with
As
a result of the
NRC inspection,
violations of NRC
regulatory requirements
were identified and the report documenting the
NRC
inspection
was sent to you by letter dated October
7,
1994.
An enforcement
conference
was conducted
in the
NRC Region II office on October
21,
1994, to
discuss
the violations, their cause,
and your corrective actions to preclude
recurrence.
This enforcement
conference
was
open for public observation
in
accordance
with the Commission's trial program for conducting
open enforcement
conferences
as discussed
in the Federal
Re ister,
57 FR 30762, July 10,
1992,
and
59 FR 36796, July 19,
1994.
A summary of this conference
was sent to you
by letter dated October
28,
1994.
Violation A, described
in the enclosed
Notice of Violation (Notice), involves
inadequate
design control for the
ESW system in that
a single failure in the
system could result in the loss of
ESW train independence.
Specifically, in
the event
a safety injection signal
was initiated concurrently with a loss of
offsite power,
the failure of the train "A" auxiliary reservoir return valve,
1SW-270, to open,
could ca'use
a previously unanalyzed
reverse
flow path through
the "A" train emergency
diesel
generator jacket water heat exchanger.
The
resulting backflow of high temperature
water through the charging safety
injection pump coolers could damage all three
pumps.
Following your initial
discovery of the reverse
flow problem,
you initiated action in which the
opposite train
ESW isolation valves
on the charging pumps'il cooler outlets
were closed.
This action
was subsequently
determined to be inappropriate
and
would have resulted
in an increase
in the rate of heatup of the
ESW cooling
water if the event occurred.
In addition,
you found that the integrity of the
ESW piping in the charging safety injection pump rooms would be challenged
by
expansion
from temperatures
exceeding
the design
and could not be assured
unless
operator action
was taken promptly.
This vulnerability existed
from
initial power operations
in January
1987, until July 18,
1994.
< ~O < ~ 0
ADOCK 05000400
9411290226 94iii7
6
CPLL
10 CFR 50, Appendix B, Criterion III requires that measures
be established
to
assure
that applicable regulatory requirements
are correctly translated
into
system specifications.
FSAR section 9.2. 1, Service
Water System,
states
that
the service water system is designed
to provide
a heat sink for essential
loads
assuming
a single active failure in conjunction with a loss of offsite power.
Essential
loads referenced
in Table 9.2. 1-1 of the
FSAR included the charging
pump oil coolers.
In addition,
Technical Specification 3.7.4 requires
two
independent trains of ESW.
With regard to Violation A, the
NRC is concerned
.
that you failed to establish
adequate
design control
measures
to identify that
a single failure, i.e., the failure of valve
1SW-270 to open,
could result in
an
ESW system train interaction that affected the capability to cool the
charging safety injection pumps.
Generic Letter 89-13, Service
Water System
Problems Affecting Safety-Related
Equipment,
recommended
that specific reviews
system single failure issues
be undertaken.
Your engineering
review process
conducted
in response
to the generic letter was not well
defined; accountability for the overall service water system
program review was
not established;
and,
no records of final management
review and approval of the
single failure reviews were found.
These
weaknesses
indicate that your program
was neither indepth nor well controlled.
Although the
NRC agrees
that the probability of occurrence
of an event of this
type is low, the safety
consequences
are high in that all three charging
pumps
and the emergency
diesel
generator jacket water cooler on the
A train could
be
damaged.
Based
on this
and the fact that specific reviews of service water
system single failure issues
were
recommended
by Generic Letter 89- 13 because
of previous industry issues
in this area,
your failure to identify this
deficiency is
a significant concern.
Therefore, this violation has
been
categorized
The
NRC recognizes
that specific corrective actions
were taken in response
to
the violation as discussed
during the enforcement
conference.
Those actions
included
(1) changing the valve lineup of the
ESW system to separate
the
trains;
(2) updating the single failure review of the
ESW system;
and,
(3) performing
a review of cross
connections
in other
decay heat
removal
systems.
You also indicated that you plan to conduct
a service water system
operational
performance
inspection in late
1994
and will conduct single failure
training for appropriate
nuclear engineering
personnel.
In accordance
with the "General
Statement of Policy and Procedure for NRC
Enforcement Actions" (Enforcement Policy),
a civil
penalty is considered for a Severity Level III violation.
Considering your
identification of the violation, prompt
and extensive corrective actions taken
following that identification,
and good past performance
balanced againstthe
facts that you failed to identify this violation during
a prior opportunity in
your Generic Letter 89-13 review of the
ESW system
and the violation had
existed for an extensive period of time, the base civil penalty for the
violation has
been fully mitigated.
Violation
B described
in the enclosed
Notice involved your failure to provide
complete
and accurate
information in a letter to the
NRC responding
and dated
June
17,
1991.
Your initial activities, testing
and
CPKL
continuing program were documented
in
a response
to Generic Letter 89-13 dated
January
26,
1990.
The June
17,
1991 letter stated that,
as of May 20,
1991,
the date of startup
from the
1991 refueling outage,
"the initial activities,
testing
and establishment
of the continuing program to which CPKL committed"
were completed.
In fact, all actions
were not completed.
The
NRC identified
an example where single failure reviews were not completed
and documented prior
to startup
from the
1991 refueling outage.
The violation was caused
by
a lack
of attention to detail
in confirming that commitments to the
NRC were completed
because
of your poor engineering
review process,
failure to control the service
'ater
system
program review,
and inadequate
records of completion of the
Generic Letter 89-13 action items.
Additionally, during the enforcement
conference
you indicated that your staff had identified three other
discrepancies
in implementation of the generic letter commitments.
These
examples
included deferring the test of the "8" charging safety injection
pump
oil coolers
beyond the committed date; establishing
a retesting
frequency that
did not meet the generic letter;
and failing to conduct reviews of the
maintenance
practices,
operations
and emergency
procedures,
and training for
the component cooling water system or the essential
chill water system.
These
additional three
examples
are not being cited with the
NRC identified violation
because
you identified these violations
and took prompt
and appropriate
corrective actions.
The
NRC requires that information provided
by licensees
be complete
and
accurate
in all material respects.
Although the specific examples of
inaccurate
information were not of substantial
safety significance, this matter
is of regulatory concern
because
your staff did not make
an adequate effort to
ensure that its statements
and representations
to the
NRC were complete
and
accurate
in all material respects.
For these
reasons,
the
NRC is issuing
a
Severity Level
IV violation in this case.
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 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter and its enclosure will be placed in the
NRC Public Document
Room
(PDR).
Accordingly, your response
should not to the extent possible,
include
any personal
privacy, proprietary,
or safeguards
information so that it cari
be'eleased
to the public and placed in the
PDR without redaction.
However, .if=
you find it necessary
to include such information, you should clearly indicate
the specific information that you believe should not be placed in the
PDR,
and
provide the legal basis to support your request for withholding the information
from the public.
CPKL
The responses
directed
by this letter
and the enclosed
Notice are not subject
to the clearance
procedures
of the Office of Management
and
Budget
as required
by the Paperwork
Reduction Act of 1980,
Pub.
L. No.96-511.
Should you have
any questions
concerning this letter,
please
contact
us.
Sincerely,
Docket No. 50-261
License
No.
EA 94-204
Stewart
D. Ebnater
Regional
Adminis
ator
Enclosure:
cc w/encl:
H.
W. Habermeyer,
Jr.
Vice President
Nuclear Services
Department
Carolina
Power
II Light Company
P. 0.
Box 1551
- Mail OHS7
Raleigh,
NC
27602
J.
W. Donahue
Plant Manager
- Harris Plant
Carolina
Power
& Light Company
Shearon Harris Nuclear
Power Plant
P. 0.
Box 165,
MC:
Zone
1
New Hill, NC
27562-0165
cc w/encl cont'd:
(See next page)
cc w/encl cont'd:
David McCarthy,
Manager
Regulatory Affairs
Harris Nuclear Project
P. 0.
Box 165
New Hill, NC
27562
H.
Ray Starling
Manager
- Legal
Department
Carolina
Power
and Light Co.
P. 0.
Box 1551
Raleigh,
NC
27602
Dayne
H. Brown, Director
Division of Radiation Protection
N.
C. Department of Environmental
Commerce
II Natural
Resources
P. 0.
Box 27687
Raleigh,
NC
27611-7687
Karen
E.
Long
Assistant Attorney General
State of North Carolina
P. 0.
Box 629
Raleigh,
NC
27602
Public Service
Commission
State of South Carolina
P. 0.
Box 11649
Columbia,
SC
29211
Admiral Kinnaird R.
McKee
214 South Morris Street
Oxford,
21654
Robert
D. Martin
3382
Sean
Way
Lawrenceville,
GA
30244
The Honorable
Hugh Wells
Chairman of the North Carolina
Utilities Commission
P. 0.
Box 29510
Raleigh,
NC
27626-0510
Robert
P. Gruber
Executive Director
Public Staff NCUC
P. 0.
Box 29520
Raleigh,
NC
27626
CPE(L
Distribution w/encl:
LPDR
SECY
CA
JTaylor,
JHilhoan,
DEDR
SEbneter,
RII
RZimmerman,
LChandler,
JGoldberg,
Enforcement
Coordinators
RI, RIII, RIV
JLieberman,
HSatorius,
EHayden,
HHiller, OC
DDandois,
OC
LTremper,
OC
JFitzgerald,
EJordan,
DWilliams, OIG
OE:EA (2)
HChristensen,
RII
CEvans,
RII
BUryc, RII
KClark, RII
PLohaus,
RTrojanowski, RII
IHS:RII
NUDOCS
N. Le,
G. A. Hallstrom, RII
PUBLIC
NRC Resident
Inspector
U. S. Nuclear Regulatory
Commission
5421
Shearon Harris
Road
New Hill, NC
27562-9998