ML18009A317

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
Issue date:	12/21/1989
From:	RICHEY R B CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-694 NUDOCS 9001020244
Download: ML18009A317 (6)

See also: IR 05000400/1989021

Text

P]F>IIIBUTIO'N

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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:NTERNAL: EC Z PI E'NT ZD CODE/NAMF PD2-1 PD ACRS A OD/DEZZB D"DRO NRR/DLPQ/LPEB10

NRR/DREP/PEPB9D

NRR/DRIS/DIR

NRR/PMAS/ZLRB12

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

NRR/DOEA DZR 11 NRR/DREP/PRPB1

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS1 RES MORZSSEAU,D

COPIES LTTR ENCL 1 1 EfiTERNAL:

L~DR NS1C NRC PDR 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 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

Commission

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:

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 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

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