IR 05000261/1987015
| ML14191A863 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/18/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14191A864 | List: |
| References | |
| EA-87-112, NUDOCS 8709280055 | |
| Download: ML14191A863 (4) | |
Text
SEP 18 1987 Docket No. 50-261 License No. DPR-23 EA 87-112 Carolina Power and Light Company TTN:
Mr. E. E. Utley Senior Executive Vice President Power and Supply and Engineering and Construction P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRV c
INSPECTION REPORT NOS. 50-261/87-15 AND 50-261/87-23)
This refers to the inspection conducted on May 11 - June 12, 1987, at the cI H. B. Robinson Plant. The inspection included a review of the circumstanc c3 surrounding the isolation of the low pressure safety injection system on J e
.1987 and the subsequent isolation of. two of three high pressure safety inj tion flow paths on June 11, 1987. Both events were identified by the plant sta and reported to the NRC. The report documenting.this inspection was sent to you by letter dated June 18, 1987. As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on June 26, 1987. The report documenting this conference was sent to you by letter dated July 24, 198 The violations associated with items I.A and I.B involve the isolation of both trains of low pressure safety injection in violation of Technical Specification requirements. This was cau.sed by the failure to comply with station procedures concerning the control of valve lineup activities. It was fortunate that, due to a required cooldown for the repair of an unrelated problem, the unit never reached critical operation, and the mispositioned valve was identified and cor rected. This valve was not part of any locked valve surveillance program and, therefore, your routine programmatic activities would not have prevented the low pressure safety injection system from.being inoperable for an extended period of power operation. Only an unrelated maintenance problem appears to have prevented this disabling of a safety system from becoming a more significant conditio Item I.B demonstrates weaknesses in your valve lineup and independent verifica tion mechanisms and caused the isolation of the low pressure safety injection system for approximately 42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />, from June 5 to June 7, 1987. The breakdown in these work control mechanisms may indicate a lack of appreciation for the safety significance of the independent verification process on the part of some of your staff. The auxiliary operators did not have a copy of the valve lineup in their possession when aligning the valves. While using the actual valve lineup sheets, or copies thereof, is not a specific requirement, not doing 8709280055 870918 PDR ADOCK 05000261 G
Carolina Power and Light Company
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SEP18 1987 so may demonstrate an informal, complacent attitude about this important safety verification activity. Safety-related valve manipulation and independent verification are activities affecting quality which are fundamental concepts for ensuring the-correct performance of operations. The failure to verify the valve lineup on June 5, 1987, in the required independent manner, is of-concern because of the casual attitudes and work habits that your auxiliary operators may be developing as they progress to more responsible positions as reactor operators and senior reactor operators. Finally, contrary to procedures, the senior reactor operator initialed the valve lineup sheet although he did not personally perform the valve lineup. This is of concern in that for a senior member of your operating staff to participate in such practices where safety significant activities are involved is absolutely unacceptabl Item II involves the failure to follow procedures resulting in the valving out of two of three high pressure safety injection flow paths by a licensed operato During the performance of General Procedure GP-007 (Rev. 9), "Plant Cooldown from Hot Shutdown", the three accumulator isolation valves were required to be shut. However, both Safety Injection Pump Discharge Header Cross-Connect Valves, SI-878A and SI-878B, were also shut. While the action statement for the associ ated Technical Specification was not exceeded, the misalignment was s.ignificant in that it occurred within one week of the low pressure safety injection proble The two events occurring in a short period of time reinforces the need for atten tion to operational activities by your operations staf To emphasize the need to improve independent verification, strict compliance to procedures, and attention to detail, I have been authorized, after consultation with the. Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000)
for the violations described in the enclosed Notice. In accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions," in 10 CFR Part 2, Appendix C (1987) (Enforcement Policy), the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem because they collectively indicate a weakness in the control of valve operations. The base value of a civil penalty for a Severity Level III violation or problem is $50,00 It is recognized that the violations were identified and reported by your staff and that your past performance in the area of concern has been good. Also, your long term corrective actions following these two events were extensive. However, the violations involved four individu als making significant errors. The first item had the potential for an increase in safety significance had the low pressure injection system remained isolated during power operation. While your staff identified the problem concerning the mispositioned valve which blocked the low pressure injection path, your staff had several earlier opportunities to identify the problem but failed to take advantage of those opportunities because of their failure to follow procedures. The second event, which involved a licensed operator, demonstrates that immediate corrective actions for the first event were not effectiv Therefore, after considering the escalation and mitigation factors in the NRC Enforcement Policy, no adjustment has been deemed appropriat You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your
Carolina Power and Light Company 3SEP 18198 response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements. Additionally, your future plant operations will be closely reviewed to assure the NRC that these events are, in fact, isolated problem In accordance with Section 2.790 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 Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51
Sincerely, ORIGINAL SIGNED BY J. Nelson Grace Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cw/encl:
. Beatty, Jr., Vice President Robinson Nuclear Project Department L.R E. Morgan, Plant General Manager
Carolina Power and Light Company
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