ML20197H090
| ML20197H090 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/10/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| References | |
| 50-324-97-12, 50-325-97-12, EA-97-521, NUDOCS 9712310188 | |
| Download: ML20197H090 (4) | |
See also: IR 05000324/1997012
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December 10, 1997
EA 97 521-
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Carolina Power and Light Company
ATTN:~Mr. C. S. Hinnant
Vice President
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Brunswick Steam Electric Plant
P. O. Box 10429
Southport, North Carolina 28461
-SUBJECT:
EXERCISE OF ENFORCr. MENT DISCRETION
(NRC-INTEGRATED INSPECTION REPORT 50 325, 324/97 12)
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Jear Mr. Hinnant:
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- On November 8,1997, the NRC completed an inspaction at your Brunswick reactor
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facility. You were informed of the inspection findings in an exit interview
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conducted on November 13. 1997. The results of that inspection were
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documented in NRC Inspection Report 50 325(324)/97 12.
During the inspection, the NRC examined Carolina Power and Light Company's
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(CP&L) review related to IF 300 Spent Fuel Cask activities. On December 24,
1996, the NRC requested additional information from CP&L regarding NRC
Bulletin 92 02, Movement of Heavy Loads Over Spent Fuel, Over Fuel in the
Reactor Core, or Over Safety Related Equipment. During CP&L's review
undertaken in response to our request..your staff determined that certain
spent fuel shipping cask handling activities had been ronducted outside the
design and licensing bases of the Brunswick plant.
Specifically, the cask was
lifted from the primary, non single failure proof lift to the second1ry lift
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. ith the valve box covers removed. Movement in this manner was not addressed
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in the shipping cask configuration drop analysis. Consequently. CP&L stopped
-any further cask movement. The condition was reported to the NRC in
accordance with 10 CFR 50.73 on June 5, 1997 (Licensee Event Report (LER) 50-
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325, 324/97 04). On August 6, 1997. CP&L submitted a request for NRC review
of the condition after concluding the issue involved an unreviewed safety
' question (USQ).
Updated Final Safety Analysis Report (UFSAR), Section 9.1.4.2.3.2. Safety
- Analysis,- states that a drop of the spent fuel cask during transfer is
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extremely improbable, in part, because redundancy is employed in all vital
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mrtion's of the cask hoisting mechanism and conservative design margins have
men used for cask related handling equi ment. Although the UFSAR did not
-specifically discuss movement-of the cast with the valve box covers removed,
the underlying safety analysis for cask movement assumed the cask was in the
shipping configuration with the valve covers installed,
Movement of the spent
fuel cask with a non single failure proof lift and with less than the full
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- cask integrity constituted-a change to the facility. The change had not been
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' adequately:USQ as documented in CP&L's letter to the NRC dated August 6 1997
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evaluated in any safety evaluation, pursuant to 10 CFR 50.59,-and
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' involved'a
-Movement of the cask without the val te covers installed has occurred a number
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iof times-at the Brunswick facility.
M. ag g M Sa4
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Based on the information deveload during the inspection, the NRC has
determined that a violation of iRC requirements occurred. The failure to
identify a USQ and seek a licensee amendment is generally characterized as a
Severity Level III violation in accordance with the " General Statement of
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Policy and Procedures for Enforcement Acwns" (Enforcement Policy). NUREG-
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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
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civil penalty for a Severity Level III violation which involves old design
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. issues,
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After review of this violation and 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
enforcement discretion are: (1) the movement of the spent fuel cask with the
valve cover removed is considered an old design issue in that the failure to
analyze the cask in that configuration had existed since initial licensing and
there had been no prior notice so that CP&L could have reasonably identified
the violation earlier: (2) you were unaware of the departure from the UFSAR
description until a similar error was identified at your Harris plant;
additionally, your followu) on the NRC questions was thorough, resulting in
the identification of the JSQ: (3) your corrective actions were comprehensive
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and timely: (4) the issue was not likely to be identified by routine
surveillance or quality assurance reviews of the cask activity; and (5) you
promptly reported the condition to the NRC.
In addition, a descri
30, 1996,ption of
your FSAR review program was presented to the NRC on May
and is
docketed in a meeting summary issued by the NRC on June 10, 1996.
Based on
NRC's assessment-of the scope and thoroughness of your FSAR review program, it
is possible that this would have been identified regardless of the NRC
Bulletin.
This letter closes apparent violation EEI 50 325. 324/97 12 09 and no formal
response to the apparent violation is required. NRC's final evaluation of
your corrective actions will be addressed during the review arm closecut of
LER.
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
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Regional Administrator
Docket Nos. 50 325, 50 324
cc: See page.3
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CC:-
Director
Assistant Attorney General
Site-Operations
State of North Carolina
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Brunswick Steam Electric Plant.
P. O. Box 629
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P. O. Box 10429
Raleigh, NC 27602
Southport, NC 28461
Executive Director
J. J. Lyash
Public Staff
NCUC
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Plant Manager
P. O. Box 29520
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Brunswick Steam Electric Plant
Raleigh NC- 27626 0520
Carolina Power & Light Company
P. O. Box 10429
Public Service Commission
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Southport, NC 28461
State of South Carolina
P. O. Box 11649
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O. B. Alexander, Manager
Columbia. SC 29211
Performance Evaluation and
Regulatory Affairs
OHS 7
Chairman
Carolina Power & Light Company
Brunswick County Board of
412 S. Wilmington Street
Commissioners
Raleigh, NC- 27601
P. O. Box 249
Bolvia, NC 28422
K. R. Jury. Manager
Regulatory Affairs
Emergency Management Coordinator
Carolina Power & Light Company
New Hanover County Department of
Brunswick Steam Electric Plant
Emergency Management
P. O. Box 10429
P. O. Box 1525
Southport. NC 28461 0429
Wilmington, NC 28402
W. D. Johnson, Vice President
Mayor
and Senior Counsel
City of Southport
Carolina Power & Light Company
201 East Moore Street
P, O. Box 1551
Southport, NC 28461
Rbleigh. NC 27602
Director
Division of Radiation Protection
N. C. Department of Environmental
Health & Natural Resources
3825 Barrett Drive
Raleigh, NC 27609 7721
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Distriystion:
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J. Lie mrman. OE
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06:EA File (BSu,,aers)(2)
A. Boland, RII
H, Shymlock, RII
D. Trimble. NRR
J. Coley. RII
R. Baldwin, RII
J. Lenahan. RII
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W. Rankin, RII
0. Thompson, RII
PUBLIC-
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
8470 River Road. SE-
Southport, NC 28461
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