IR 05000348/1998003: Difference between revisions

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EXERCISE OF ENFORCEMENT DISCRETION (NRC INTEGRATED INSPECTION REPORT 50-348/98-03. 50-364/98-03)
.   .
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July 10. 1998 EA 98-351 Southern Nuclear Operating Company. Inc.


ATTN: Mr. D. Vice President P. O. Box 1295 Birmingham. AL 35201-1295 SUBJECT: EXERCISE OF ENFORCEMENT DISCRETION (NRC INTEGRATED INSPECTION REPORT 50-348/98-03. 50-364/98-03)
==Dear Mr. Morey:==
On May 30, 1998, the Nuclear Regulatory Commission (NRC) completed an inspection at Southern Nuclear Company's (SNC) Farley facility.


==Dear Mr. Morey:==
The results of that inspection were discussed at an exit meeting conducted on June 4. 1998, and documented in NRC Inspection Report No. 50-348/98-03.
On May 30, 1998, the Nuclear Regulatory Commission (NRC) completed an inspection at Southern Nuclear Company's (SNC) Farley facility. The results of that inspection were discussed at an exit meeting conducted on June 4. 1998, and documented in NRC Inspection Report No. 50-348/98-03.


50-364/98-03 issued on July 1. 1998.
50-364/98-03 issued on July 1. 1998.
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The issue involved five mis-wired motor-operated valves (MOVs) at the hot shutdown panel (HSDP) for each unit (10 MOVs in total) that could have adversely impacted the ability of operators to safely shut down and cool down the plant in the event of a fire in the main control room (MCR) or cable spreading room (CSR). Specifically, during fuse ins]ections conducted on May 23 and 25, 1997 licensee personnel identified tlat the portion of the control circuitry which is used to select either local (HSDP) or remote (MCR)
The issue involved five mis-wired motor-operated valves (MOVs) at the hot shutdown panel (HSDP) for each unit (10 MOVs in total) that could have adversely impacted the ability of operators to safely shut down and cool down the plant in the event of a fire in the main control room (MCR) or cable spreading room (CSR). Specifically, during fuse ins]ections conducted on May 23 and 25, 1997 licensee personnel identified tlat the portion of the control circuitry which is used to select either local (HSDP) or remote (MCR)
mode of operation was found to have the associated control power fuses wired in series rather than in parallel. In this configuration, any fault which resulted in the opening of either fuse would have prevented operation of the valve from the HSDP location. The remote (MCR) mode of operation would have o)erated as designed and would only have been lost in the event of a fault w11ch opened its associated control power fuse. For each unit, the five affected MOVs were two oower operated relief valve block valves. two refueling waterstoragetanktochargingpumpsuctionisolationvalves,andacomponent cooling water to secondary heat exchanger isolation valve. SNC determined that the improper wiring occurred during the implementation of design changes performed in 1985 to establish local-remote operation capability in response to 10 CFR 50. Appendix R requirements for alternate shutdown capability. This j/,
mode of operation was found to have the associated control power fuses wired in series rather than in parallel.
issue is fully described in NRC Inspection Report No. 50-348/98-03. /'7 50-364/98-03, as well as Licensee Event Report (LER) 50-348. 364/97-010-00, dated June 20. 1997, and a revision to the LER (50-348, 364/97-010-01). dated April 29. 1998.
 
In this configuration, any fault which resulted in the opening of either fuse would have prevented operation of the valve from the HSDP location.
 
The remote (MCR) mode of operation would have o)erated as designed and would only have been lost in the event of a fault w11ch opened its associated control power fuse.
 
For each unit, the five affected MOVs were two oower operated relief valve block valves. two refueling waterstoragetanktochargingpumpsuctionisolationvalves,andacomponent cooling water to secondary heat exchanger isolation valve.
 
SNC determined that the improper wiring occurred during the implementation of design changes performed in 1985 to establish local-remote operation capability in response j/
to 10 CFR 50. Appendix R requirements for alternate shutdown capability. This issue is fully described in NRC Inspection Report No. 50-348/98-03.
 
/'7
,
50-364/98-03, as well as Licensee Event Report (LER) 50-348. 364/97-010-00, dated June 20. 1997, and a revision to the LER (50-348, 364/97-010-01). dated April 29. 1998.


Based on the information developed during the inspection. the NRC has determined that this issue constitutes a violation of regulatory requirements.
Based on the information developed during the inspection. the NRC has determined that this issue constitutes a violation of regulatory requirements.


10 CFR 50. Appendix R. III.L.7 states that the isolation of associated 9807160302 980710 PDR ADOCK 05000348 G PDR
10 CFR 50. Appendix R. III.L.7 states that the isolation of associated 9807160302 980710 PDR ADOCK 05000348 G
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Ib 0


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SNC  2 circuits from safe shutdown equipment shall be such that a fire involving associated circuits will not prevent safe shutdown. The control circuits for the five MOVs on each unit at the HSDP required for alternate shutdown capability were not independent of control circuits in the MCR and CSR because the control power fuses were wired in series rather than parallel. As such, a fire-induced electrical fault which resulted in opening of either fuse would have prevented operation of the subject valves from the HSDP location.
s.


SNC identified that in the event of a fire in the MCR or CSR. coincident with a loss of offsite power the potential . existed for a loss of cooling accident-to occur due to the loss of cooling to the Reactor Coolant Pump (RCP) seals.
..
.
SNC


Loss of cooling to the RCP seals would result from a loss of seal injection and component cooling water flow to the thermal barrier heat exchanger. Under certain fire-induced failure conditions. the centrifugal charging pump (CCP)
circuits from safe shutdown equipment shall be such that a fire involving associated circuits will not prevent safe shutdown.
suction could be lost resulting in possible vapor binding and damage to the operating CCP. In addition., a fire-induced spurious valve closure could isolate component cooling water supply flow to the RCP thermal barrier. As such. the mis-wired MOV control circuitry had the potential to prevent safe shutdown of the unit. contrary to 10 CFR 50. Ap]endix R. II.L.7 requirements.
 
The control circuits for the five MOVs on each unit at the HSDP required for alternate shutdown capability were not independent of control circuits in the MCR and CSR because the control power fuses were wired in series rather than parallel.
 
As such, a fire-induced electrical fault which resulted in opening of either fuse would have prevented operation of the subject valves from the HSDP location.
 
SNC identified that in the event of a fire in the MCR or CSR. coincident with a loss of offsite power the potential. existed for a loss of cooling accident-to occur due to the loss of cooling to the Reactor Coolant Pump (RCP) seals.
 
Loss of cooling to the RCP seals would result from a loss of seal injection and component cooling water flow to the thermal barrier heat exchanger.
 
Under certain fire-induced failure conditions. the centrifugal charging pump (CCP)
suction could be lost resulting in possible vapor binding and damage to the operating CCP.
 
In addition., a fire-induced spurious valve closure could isolate component cooling water supply flow to the RCP thermal barrier. As such. the mis-wired MOV control circuitry had the potential to prevent safe shutdown of the unit. contrary to 10 CFR 50. Ap]endix R. II.L.7 requirements.


A violation involving a safety-related system w1ich is unable to perform its intended safety function under certain conditions is generally characterized as a Severity Level III violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions" (Enforcement Policy).
A violation involving a safety-related system w1ich is unable to perform its intended safety function under certain conditions is generally characterized as a Severity Level III violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions" (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 old design issues.
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 old design issues.


After review of this violation and consultation with the Director. Office of Enforcement, the NRC has concluded that while a violation did occur..
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 included: your staff's identification of the deficiency during non-routine fuse inspections; your staff's prompt extent of condition review and re-wiring of the affected MOVs in accordance with design requirements; the deficiency is considered an old design inue which was not likely to be identified through routine licensee efforts; this issue is not reflective of current licensee performance; and the deficiency was. j appropriately reported to the NRC. i This letter closes-apparent violation EEI 50-348.364/98-03-05, and no formal response to this letter is required.
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 included: your staff's identification of the deficiency during non-routine fuse inspections; your staff's prompt extent of condition review and re-wiring of the affected MOVs in accordance with design requirements; the deficiency is considered an old design inue which was not likely to be identified through routine licensee efforts; this issue is not reflective of current licensee performance; and the deficiency was.
 
appropriately reported to the NRC.
 
j i
This letter closes-apparent violation EEI 50-348.364/98-03-05, and no formal response to this letter is required.


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I SNC
 
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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.


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  , .
I SNC  3
      .
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice." a copy of I this letter will be placed in the NRC Public Document Room. j l


Sincerely
Sincerely
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l
      )
)
original signed by LAR i
original signed by LAR i
Luis A. Reyes Regional Administrator i
Luis A. Reyes Regional Administrator i
Docket Nos. 50-348 and 50-364 License Nos., NPF-2 and NPF-8 l
Docket Nos.
I


      !
50-348 and 50-364 License Nos.,
l
NPF-2 and NPF-8


Il
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SNC   4 cc w/encls:
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SNC
 
cc w/encls:
M. J, Ajluni. Licensing Services Manager B-031 Southern Nuclear Operating Company. Inc.
M. J, Ajluni. Licensing Services Manager B-031 Southern Nuclear Operating Company. Inc.


Line 101: Line 146:
P. O. Box 1295 Birmingham. AL 35201-1295 J. D. Woodard Executive Vice President Southern Nuclear Operating Company. Inc.
P. O. Box 1295 Birmingham. AL 35201-1295 J. D. Woodard Executive Vice President Southern Nuclear Operating Company. Inc.


P. O. Box 1295-Birmingham, AL 35201-1295 State Health Officer Alabama Department of Public Health 434 Monroe Street f Montgomery, AL 36130-1701 1 M.-Stanford Blanton Balch and Bingham Law Firm P. O. Box 306 1710 Sixth Avenue North Birmingham. AL 35201 Chairman Houston County Commission P. O. Box 6406 Dothan. AL 36302 l
P. O. Box 1295-Birmingham, AL 35201-1295 State Health Officer Alabama Department of Public Health 434 Monroe Street f
Montgomery, AL 36130-1701
 
M.-Stanford Blanton Balch and Bingham Law Firm P. O. Box 306 1710 Sixth Avenue North Birmingham. AL 35201 Chairman Houston County Commission P. O. Box 6406 Dothan. AL 36302 l
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SNC   4  J Distribution:
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L#allan. EDO     l HThompson. DEDR     I AThadani. DEDE     I LChandler. 0GC JGoldberg. OGC.
SNC
 
J Distribution:
L#allan. EDO l
HThompson. DEDR I
AThadani. DEDE I
LChandler. 0GC JGoldberg. OGC.


EJulian. SECY BKeeling. CA Enforcement Coordinators RI. RIII, RIV JLieberman. OE WBeecher..OPA GCaputo. OI-TMartin.-AEOD HBell. DIG CEvans. RII KClark. RII LPlisco RII'
EJulian. SECY BKeeling. CA Enforcement Coordinators RI. RIII, RIV JLieberman. OE WBeecher..OPA GCaputo. OI-TMartin.-AEOD HBell. DIG CEvans. RII KClark. RII LPlisco RII'
BMallett RII PSkinner. RII     i; MTschiltz. OED0     l ABoland. RII     4 SSparks RII     l L01shan. NRR     :
BMallett RII PSkinner. RII i
TReis. OE     l RCarrion. RII OE:EA File (BSummers. OE)(2 letterhead)
MTschiltz. OED0 l
ABoland. RII
 
SSparks RII l
L01shan. NRR
:
TReis. OE l
RCarrion. RII OE:EA File (BSummers. OE)(2 letterhead)
PUBLIC i
PUBLIC i
NRC Resident Inspector     !
NRC Resident Inspector
!
U. S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia. AL 36319 h
U. S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia. AL 36319 h
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Signature
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g NAME LPLI$l0 CEVA B AO JJA f)OHNSON DATE N 1, J.91L i/ k /98
/ h /98 7/[/ /98 7 / / O /98
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YES YES NO YES YES NO OFFICIAL RECORD M Y DOCupiENT NAME M 1980 PEN.ENF\\98351FAR.DIR\\DISCLTR. V l
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}}
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Latest revision as of 00:35, 3 December 2024

Informs That on 980530,NRC Completed Insp Repts 50-348/98-03 & 50-364/98-03 for Facility.Issue Re 5 mis-wired MOVs at Hot Shutdown Panel for Unit That Could Have Adversely Impacted Ability of Operators to Shut Down Plant,Were Examined
ML20236P407
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 07/10/1998
From: Reyes L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
References
50-348-98-03, 50-348-98-3, 50-364-98-03, 50-364-98-3, EA-98-351, NUDOCS 9807160302
Download: ML20236P407 (5)
v • d • e


Text

SUBJECT:

EXERCISE OF ENFORCEMENT DISCRETION (NRC INTEGRATED INSPECTION REPORT 50-348/98-03. 50-364/98-03)

Dear Mr. Morey:

On May 30, 1998, the Nuclear Regulatory Commission (NRC) completed an inspection at Southern Nuclear Company's (SNC) Farley facility.

The results of that inspection were discussed at an exit meeting conducted on June 4. 1998, and documented in NRC Inspection Report No. 50-348/98-03.

50-364/98-03 issued on July 1. 1998.

During the inspection, the NRC examined an issue discovered by SNC in 1997.

The issue involved five mis-wired motor-operated valves (MOVs) at the hot shutdown panel (HSDP) for each unit (10 MOVs in total) that could have adversely impacted the ability of operators to safely shut down and cool down the plant in the event of a fire in the main control room (MCR) or cable spreading room (CSR). Specifically, during fuse ins]ections conducted on May 23 and 25, 1997 licensee personnel identified tlat the portion of the control circuitry which is used to select either local (HSDP) or remote (MCR)

mode of operation was found to have the associated control power fuses wired in series rather than in parallel.

In this configuration, any fault which resulted in the opening of either fuse would have prevented operation of the valve from the HSDP location.

The remote (MCR) mode of operation would have o)erated as designed and would only have been lost in the event of a fault w11ch opened its associated control power fuse.

For each unit, the five affected MOVs were two oower operated relief valve block valves. two refueling waterstoragetanktochargingpumpsuctionisolationvalves,andacomponent cooling water to secondary heat exchanger isolation valve.

SNC determined that the improper wiring occurred during the implementation of design changes performed in 1985 to establish local-remote operation capability in response j/

to 10 CFR 50. Appendix R requirements for alternate shutdown capability. This issue is fully described in NRC Inspection Report No. 50-348/98-03.

/'7

,

50-364/98-03, as well as Licensee Event Report (LER) 50-348. 364/97-010-00, dated June 20. 1997, and a revision to the LER (50-348, 364/97-010-01). dated April 29. 1998.

Based on the information developed during the inspection. the NRC has determined that this issue constitutes a violation of regulatory requirements.

10 CFR 50. Appendix R. III.L.7 states that the isolation of associated 9807160302 980710 PDR ADOCK 05000348 G

PDR

-

- - - - - -

Ib 0

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

'

.

.

s.

..

.

SNC

circuits from safe shutdown equipment shall be such that a fire involving associated circuits will not prevent safe shutdown.

The control circuits for the five MOVs on each unit at the HSDP required for alternate shutdown capability were not independent of control circuits in the MCR and CSR because the control power fuses were wired in series rather than parallel.

As such, a fire-induced electrical fault which resulted in opening of either fuse would have prevented operation of the subject valves from the HSDP location.

SNC identified that in the event of a fire in the MCR or CSR. coincident with a loss of offsite power the potential. existed for a loss of cooling accident-to occur due to the loss of cooling to the Reactor Coolant Pump (RCP) seals.

Loss of cooling to the RCP seals would result from a loss of seal injection and component cooling water flow to the thermal barrier heat exchanger.

Under certain fire-induced failure conditions. the centrifugal charging pump (CCP)

suction could be lost resulting in possible vapor binding and damage to the operating CCP.

In addition., a fire-induced spurious valve closure could isolate component cooling water supply flow to the RCP thermal barrier. As such. the mis-wired MOV control circuitry had the potential to prevent safe shutdown of the unit. contrary to 10 CFR 50. Ap]endix R. II.L.7 requirements.

A violation involving a safety-related system w1ich is unable to perform its intended safety function under certain conditions is generally characterized as a Severity Level III violation in accordance with the " General Statement of Policy and Procedures for Enforcement Actions" (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 old design issues.

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 included: your staff's identification of the deficiency during non-routine fuse inspections; your staff's prompt extent of condition review and re-wiring of the affected MOVs in accordance with design requirements; the deficiency is considered an old design inue which was not likely to be identified through routine licensee efforts; this issue is not reflective of current licensee performance; and the deficiency was.

appropriately reported to the NRC.

j i

This letter closes-apparent violation EEI 50-348.364/98-03-05, and no formal response to this letter is required.

I

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-_

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--

- --

-

-- - - - - - - - -

- _ _ _ _ _ _ _

_ _ _ _ _ _

'

,

.

I SNC

.

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.

j

Sincerely

.

l

)

original signed by LAR i

Luis A. Reyes Regional Administrator i

Docket Nos.

50-348 and 50-364 License Nos.,

NPF-2 and NPF-8

I i

___.

- _ _ _ _ _ _ - _ _ -. _ _ _ _ _ _ - _ _ _ _ _ _ _ _

_- - _

.

.

SNC

cc w/encls:

M. J, Ajluni. Licensing Services Manager B-031 Southern Nuclear Operating Company. Inc.

42 Inverness Center Parkway Birmingham. AL 35201-1295-R. D. Hill. Jr.

General Manager. Farley Plant Southern Nuclear Operating Company. Inc.

P. O. Box 1295 Birmingham. AL 35201-1295 J. D. Woodard Executive Vice President Southern Nuclear Operating Company. Inc.

P. O. Box 1295-Birmingham, AL 35201-1295 State Health Officer Alabama Department of Public Health 434 Monroe Street f

Montgomery, AL 36130-1701

M.-Stanford Blanton Balch and Bingham Law Firm P. O. Box 306 1710 Sixth Avenue North Birmingham. AL 35201 Chairman Houston County Commission P. O. Box 6406 Dothan. AL 36302 l

l

!

_ _ _ - _ _ - _ _ _ _ _ _

_

_ - - _ - _ _ _ _ _ _ _ _ - _ _ _ _____ _ __.

'

-

.

.

.

SNC

J Distribution:

L#allan. EDO l

HThompson. DEDR I

AThadani. DEDE I

LChandler. 0GC JGoldberg. OGC.

EJulian. SECY BKeeling. CA Enforcement Coordinators RI. RIII, RIV JLieberman. OE WBeecher..OPA GCaputo. OI-TMartin.-AEOD HBell. DIG CEvans. RII KClark. RII LPlisco RII'

BMallett RII PSkinner. RII i

MTschiltz. OED0 l

ABoland. RII

SSparks RII l

L01shan. NRR

TReis. OE l

RCarrion. RII OE:EA File (BSummers. OE)(2 letterhead)

PUBLIC i

NRC Resident Inspector

!

U. S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia. AL 36319 h

o f'+

.

t

[

SEND TO PUBLIC DOCUMENT R00M7 YES RM)k OFFICE RII:DRP RII:0RA RII:DRS RII:0RV t

Signature

[

g NAME LPLI$l0 CEVA B AO JJA f)OHNSON DATE N 1, J.91L i/ k /98

/ h /98 7/[/ /98 7 / / O /98

[NO)

h k

N0

[ES]

COPY?

YES YES NO YES YES NO OFFICIAL RECORD M Y DOCupiENT NAME M 1980 PEN.ENF\\98351FAR.DIR\\DISCLTR. V l

l l.

i

'

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