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See also: [[followed by::IR 05000400/1989021]]


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{{#Wiki_filter:P]F>IIIBUTIO'N
{{#Wiki_filter:P]F>IIIBUTIO'N           Dg/Ohigi'QTl04           SYSTEM ACCESSZON NBR:9001020244                 DOC.DATE:
Dg/Ohigi'QTl04
                                              ~      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.~
SYSTEM ACCESSZON NBR:9001020244
            ~              Carolina Power ~ Light Co.       ~
DOC.DATE: 89/12/21 NOTARIZED:
RECIP.NAME               RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
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
==SUBJECT:==
RECIPIENT AFFILIATION
Responds to NRC 891108 ltr re violations noted in Znsp Rept 50-400/89-21.Corrective actions noted.
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 891108 ltr re violations
DISTRIBUTION CODE: ZE01D COPIES RECEIVED:LTR                       ENCL       SIZE:
noted in Znsp Rept 50-400/89-21.Corrective
  .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
actions noted.DISTRIBUTION
: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
CODE: ZE01D COPIES RECEIVED:LTR
 
ENCL SIZE:.ZTLE: General (50 Dkt)-Znsp Rept/Notice
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)
of Violation Response NOTES:Application
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:
for permit renewal filed.05000400:NTERNAL: EC Z PI E'NT ZD CODE/NAMF PD2-1 PD ACRS A OD/DEZZB D"DRO NRR/DLPQ/LPEB10
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.
NRR/DREP/PEPB9D
It   is considered that the corrective actions taken/planned                       are satisfactory for resolution of the item.
NRR/DRIS/DIR
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.
NRR/PMAS/ZLRB12
Thank you         for your consideration in       this matter.
0" L:"%N J 02 2 FILE Ol COPIES L TR ENCL 1 RECIPIENT ZD CODE/NAME BECKER,D AEOD AEOD/TPAD NRR SHANKMAN,S
R. B. Ricney, Man ger Harris Nuclear           P     ject MGW:dgr Attacnment cc'Mr.         R. A. Becker (NRC)
NRR/DOEA DZR 11 NRR/DREP/PRPB1
Mr. S. D. Ebneter (NRC RII)
NRR/DST/DIR
Mr. J. E. Tedrow (NRC SHNPP)
8E2 NUDOCS-ABSTRACT
MEM/HO.     B901710/1/OS1             9001020244 891221 PDR       ADQCK 05000400 8                               PNU
OGC/HDS1 RES MORZSSEAU,D
 
COPIES LTTR ENCL 1 1 EfiTERNAL:
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.
L~DR NS1C NRC PDR NOTE'ZO ALL"RIDS" RECIPEZPIS'
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.
PLEASE HELP US ZO REDOCE HASTE!COMI'ACZ'ZHE DOCUMENI'GHI'ROL
This is   a             Severity Level IV Violation (Supplement         I) ~
DESK RDCN Pl-37 (KCI'.20079)XO XZZ?GRATE YOUR NAME HtCN DISTRIBUTION
Denial or Admission and Reason                     for Violation'.
LISTS FOR DOCEGWZS YOU DON'T NEEDt TOTAL NUMBER OF COPZES REQUiRED: LTTR 26 ENCL 26  
The   violation is admitted.
l  
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.
Carolina Power&Ught Company P.O.Box 165~New Hill, N.C.27562 R.a.RCHEY Manager Hanla Nuclear Pnllect HARRIS NUCLEAR PROJECT P.O.Box 165 New Hill, North Carolina 27562 DEC 2 1 1989 Letter Number: HO-890171 (0)Document Control Desk United States Nuclear Regulatory
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.
Commission
Corrective Ste                 s Taken and Results Achieved:
Washington, DC 20555 NRC-694 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO.50-400 LICENSE NO.NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen:
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
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
Qualification Utility Group (SQUG) curves which envelope this application.
that the corrective
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.
actions taken/planned
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.
are satisfactory
Corrective Ste   s Taken   to Avoid Further Violations'.
for resolution
This incident has been reviewed by both plant and         NED personnel to avoid future miscommunication as to the scope of PCRs.
of the item.Via telephone conversation
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.
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
Date When   Full Com liance Will Be Achieved:
to the violation.
Full compliance is expected by January 31, 1990.
The reason for the extension was due to a delay in the Harris Plants receipt of the Notice of Violation.
MEM/HO-8901710/3/Osl
Thank you for your consideration
 
in this matter.R.B.Ricney, Man ger Harris Nuclear P ject MGW:dgr Attacnment
] 1}}
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 testing of critical characteristics.
During the time frame the breakers were received at HNP, testing was not being performed of received based on several breaker manufacturers
indicating
that testing was detrimental
to the breaker.include subject breakers initial 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  
]1
}}

Latest revision as of 06:39, 22 October 2019

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 Duke Energy icon.png
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

] 1