ML18012A882
| ML18012A882 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/29/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Robinson W CAROLINA POWER & LIGHT CO. |
| References | |
| 50-400-97-08, 50-400-97-8, EA-97-370, NUDOCS 9709150094 | |
| Download: ML18012A882 (8) | |
See also: IR 05000400/1997008
Text
CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:9709150094
DOC.DATE: 97/08/29
NOTARIZED: NO
FACIL:50-400 Shearon Harris Nuclear
Power Plant, Unit 1, Carolina
AUTH.NAME
AUTHOR AFFILIATION
REYESgL.A.
Region
2 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
ROBINSON,W.R.
Carolina
Power
6 Light Co.
SUBJECT: Discusses
insp rept 50-400/97-08
on 970802.Majority
deficiencies
caused
by failureto test parallel or
overlapping logic circuit paths.
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TITLE: General
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20
ENCL
SCL
EA 97-370
August 29,
1997
Carolina
Power
& Light Company
ATTN:
Hr.
W. R. Robinson
Vice President
- Harris Plant
Shearon Harris Nuclear Power Plant
P. 0. Box 165, Mail Code:
Zone
1
New Hill, NC
27562-0165
SUBJECT:
EXERCISE OF ENFORCEMENT DISCRETION
(NRC INTEGRATED INSPECTION REPORT
NO. 50-400/97-08)
Dear
Hr, Robinson:
On August 2,
1997, the
NRC completed
an inspection at Carolina
Power
8 Light
Company's
(CP&L) Harris facility.
The results of that inspection were
initially discussed
with members of your staff at the exit meeting conducted
on August 4,
1997,
and were documented in NRC Inspection Report
No. 50-400/97-08,
transmitted to you by letter
dated August 29,
1997.
During the inspection,
the
NRC examined the facts
and circumstances
'urrounding
CP&L's identification of numerous deficiencies
associated
with
logic circuit surveillance testing.
The majority of the deficiencies
were
caused
by the failure to test (1) parallel or overlapping logic circuit paths;
(2) independent circuits which caused the same actuation;
and (3) actuation of
components
which received indirect signals
from auxiliary relays following
master or slave relay actuations.
In addition, the
NRC examined five
deficiencies
associated
with test procedures
not related to logic circuits.
Based
on the information developed during the inspection,
the
NRC has
determined that
a violation of NRC requirements
occurred.
Technical Specification (TS) 4.0.1 requires that Surveillance
Requirements
shall
be met
during the Operational
Modes or other conditions specified for individual
Limiting Conditions for Operation unless otherwise stated in an individual
Surveillance
Requirement.
In addition,
TS 6.8.l.a requires that written
procedures
be established
and implemented for each surveillance test,
inspection or calibration listed in the TSs.
Between October
24,
1986, the
date the initial operating license
was issued,
and October 7, 1996,
CP8L
failed to establish
adequate
procedures to verify TS surveillance requirements/
were met for numerous safety-related
logic circuits.
Surveillance test
procedures
were also inadequate in five other cases,
one of which involved
incorrect residual
heat
removal
system alignment requirements.
As described in detail in NRC Inspection Report
No. 50-400/97-08,
these
issues
began to be identified in 1994.
However,
as
a result of review of Licensee
Event Report No. 95-07 and the reviews prior to and subsequent
to the issuance
of Generic Letter 96-01, additional deficiencies
were identified.
Due to the
programmatic nature of the issue, this violation normally would be categorized
as
a Severity Level III violation in accordance
with the "General
Statement of
llllllllllllllllllllllmglllllllllll
CPSL
Policy and Procedures
for Enforcement Action" (Enforcement Policy),
NUREG-
1600.
However,
as provided in Section VII.B.3 of the Enforcement Policy, the
NRC may refrain from issuing
a Notice of Violation (Notice)
and proposing
a
civil penalty for a Severity Level III violation which involves
a past
problem,
such
as
an old engineering,
design,
or installation deficiency,
provided that certain criteria are met.
After review of this violation and in consultation with the Director, Office
of Enforcement.
the
NRC has concluded that while a violation did occur,
enforcement discretion is warranted
and issuance of a Notice is not
appropriate in this case.
The specific bases
for the decision to exercise
(1) the majority of the testing deficiencies
were
identified by CPSL during a comprehensive
review of safety-related
logic
circuit testing following deficiencies identified early in 1995;
(2) when
retested
between
1995 and 1997, all of the affected circuits and components
performed
as required,
except in one case involving a mechanical failure;
(3) your cor rective action plan to perform the programmatic review of safety-
related logic circuit testing pre-dated the NRC's issuance of Generic Letter 96-01, Testing of Safety-Related
Logic Circuits, but incorporated the
requirements of that generic letter;
(4) the deficiencies
were not likely to
be identified as
a result of routine efforts;
(5) comprehensive
corrective
actions
have been
implemented for identified deficiencies
and further review
of TS surveillance
procedures is planned;
and (6) an improved sensitivity and
under standing of the TS requirements
related to complete logic testing
and
other TS surveillance
requirements
were demonstrated
by the thorough
identification of the above deficiencies
and procedural
enhancements
to
address
other issues.
With two exceptions,
the surveillance
program deficiencies
were reported to
the
NRC in Licensee
Event Reports in accordance
with the requirements of
as described in NRC Inspection Report
No. 50-400/97-08.
The two
exceptions
were identified by CP8L and involved exceeding the 30-day reporting
requirement.
NRC Inspection Report
No. 50-400/97-08 includes
a non-cited
violation for the late reporting of these
issues.
This letter closes the apparent violation (EEI 50-400/97-08-02)
involving
inadequate
surveillance testing of logic circuits.
Based
on the information
you have previously provided
as documented in NRC Inspection Report
No. 50-
400/97-08,
no further response
regarding this issue is required.
In accordance
with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of
this letter will be placed in the
NRC Public Document
Room.
Sincerely,
Original Signed by L. A. Reyes
Luis A. Reyes
Regional Administrator
Docket No. 50-400
License
No. NPF-63
cc:
(See
Page 4)
Distribution:
J.
Lieberman,
OE:EA File (B, Summers)(2)
H. Shymlock, RII
BE Uryc, RII
J. Coley, RII
R. Baldwin, RII
J.
Lenahan,
RII
W. Rankin, RII
D. Thompson,
RII
V. Rooney,
PUBLIC
NRC Resident
Inspector
U. S. Nuclear Regulatory Commission
5421 Shearon Harris Road
New Hill, NC
27562-9998
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OFFICIAL RECORD COPY
DOCUMENT NAME:
HN1970PEN. ENF 97370
R
SCRET. LTR