ML20150B191
| ML20150B191 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/24/1988 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8807110358 | |
| Download: ML20150B191 (4) | |
See also: IR 05000324/1987043
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~dl]N 2 41988
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: REPORT NOS. 50-325/87-42 AND 50-324/87-43
We have completed our evaluation of your March 9, 1988 response to our Notice
of Vic.ation issued on February 8,
1988, concerning activities at your
Brunswick facility.
After careful review of the basis for your denial'of the
cited Violation, we have concluded, for the reasons presented in the enclosure
to this letter, the violation occurred as stated in the Notice of Violation.
Therefore, pursuant to 10 CFR 2.201, please submit to this office within 30
days of the date of this letter, a written statement describing the reasons
for the_ violation, the corrective steps which have been taken and the results
achieved, corrective steps which will be taken to avoid further violations, and
the date when full compliance will be achieved.
In accordance with Section 2.793 of the 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 is not subject to the clearance
procedures for the Office of Management and Budget issued under the Paperwork
Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
Original Signed by
Charles W. Hehl /for
Luis A. Reyes, Director
Division of Reactor Projects
Enclosure:
Evaluation of Violation Denial
cc w/ encl:
P. W. Howe, Vice President
Brunswick Nuclear Project
C. R.jDietz, Plant General Manager
bec w/ encl:
(See page 2)
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JUN 2 41988
ENCLOSURE
EVALUATION OF VIOLATION DENIAL
The cited violation (50-325/87-42-01 and 50-324/87-43-01) involved the closure
and administrative "red tagging" of automatic containment penetration isolation
valves in an attempt to meet the "secured / deactivated" requirements of
Technical Specifications (TSs) 3.6.3 and 3.6.1.1.
The crux of your denial to
this violation is the apparent lack of specific written guidance provided by
regulation in this area and the equivalency of control taken by your operations
staff when they administratively "red tagged" the subject valves in lieu of
physical deactivation.
Although a definition of the term "deactivate" relative to valves in the
primary containment isolation system (PCIS) has not been documented, the inten't
of the use of this term in the TSs is considered to be obvious when considered
within the context of the TSs and other documents related to the functional
requirements of the PCIS.
The requirements of isolating containment penetra-
tions with two isolation valves in series are provided in General Design
Criteria 55 and 56 in Appendix A to 10 CFR Part 50. These requirements ensure
that an isolation barrier remains after a single active failure in the PCIS.
Collectively, Brunswick TSs 3.6.3 and 3.6.1.1 address this requirement by
providing alternative actions in the event that a PCIS valve is determined
to be inoperable.
The first priority is to return the inoperable valve to
operable states. The third alternative (i.e., isolating the pene'; ration with a
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closed manual valve or blind flange) removes the possibility for an active
PCIS failure to result in an open containment penetration. The method used to
deactivate an automatic PC!S valve, as required by-both TSs, in order to provide
protection equivalent to that F.cribed above can be understood by examining
the guidance provided in Standard Review Plan (SRP) 6.2.4,
"Containment
Isolation System," for sealed closed barr.iers. SRP 6.2.4 states, in part:
Sealed closed barriers may be used in place of automatic isolation valves.
Sealed closed barriers include blind flanges and sealed closed isolation
valves which may be closed manual valves, closed remote-manual valves, and
closed automatic valves which remain closed after a loss-of-coolant
accident.
Sealed closed isolation valves should be under administrative
control to assure that they cannot be inadvertently opened.
Administra-
tive control includes mechanical devices to seal or lock the valve closed,
or to prevent power from being supplied to the valve operator.
The guidance in SRP 6.2.4 is reinforced by ANSI Standard N271-1976, "Contain-
ment isolation Provisions for Fluid Systems," which defines a sealed closed
isolation valve as follows:
A valve that is in a closed position by administrative controls by any of
the following methods:
(1) A mechanical device sealing or locking the valve in the closed
position.
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JUN 2 41988
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Enclosure
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(2) A normally closed valve with a seal or. lock on any manual override
if present and a seal or lock on the power breaker or power source
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in a manner that prevents power from being supplied to the valve.
The term "seal" in the above definition is further defined as "a physical
restraint such as a lead seal." As stated above, NRC considers that mechanical
devices must be used on PCIS valves to ensure that they are sealed or locked
closed, or that power cannot be supplied to the valve operator. Only then can
the valve be considered a sealed closed barrier, and therefore, equivalent to
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redundant automatic isolation valves or a blind flange.
Nowhere in the NRC
guidance or ANSI Standard is the use of administrative tag-outs considered as
an appropriate method for ensuring containment isolation.
Based on the above, it is the NRC's position that the practice of administra-
tive "red-tagging" at Brunswick is not an acceptable method to meet the
requirements of TSs 3.6.3 and 3.6.1.1.
We therefore find that your denial
is not justified and the violation occurred as stated.
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