IR 05000261/1988003
| ML14191A936 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/15/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14191A937 | List: |
| References | |
| EA-88-088, EA-88-88, NUDOCS 8806300155 | |
| Download: ML14191A936 (5) | |
Text
JUN 15 1988 Docket No. 50-261 License No. DPR-23 EA 88-88 Carolina Power & Light Company ATTN: Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering and Construction Post Office Box 1551 Raleigh, North Carolina 27602 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-261/88-03 AND 50-261/88-04)
This refers to the NRC inspections conducted on January 11 - February 10, March 7, 1988, and February 11 - March 10, 1988, at the H. B. Robinson Plan The inspections included a review of the circumstances surrounding your identi fication of several accident scenarios during which the minimum number of safety injection (SI) pumps necessary to meet design basis requirements would not be maintained. Those potential scenarios were identified by your staff in January and February 1988, during a review conducted in response to a letter from the NRC dated January 14, 1988. The accident scenarios involved several electrical events in which two of three SI pumps would become inoperable due to a single failure. The reports documenting these inspections were sent to you by letters dated March 14 and April 27, 1988. As a result of these inspections, 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 March 30, 1988. The report documenting this conference was sent to you by letter dated April 25, 198 The violation described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved the failure of your 10 CFR Part 50, Appendix K required evaluation model to reflect the most damaging single failure relative to the ECCS safety injection (SI) subsystem. It appears that evaluations for certain single failures were not performed which resulted in the erroneous assumption that two of the three SI pumps would be operable during design basis accidents. The January/February 1988 re-evaluation conducted by you identified several electrical scenarios wherein two of the three SI pumps would become inoperable in the event of those single failures, rendering the SI function unavailable during an accident, while the evaluation model and related accident analyses described Sin the H. B. Robinson Updated Safety Analysis Report assumed two SI pumps required to be operable to accomplish the ECCS-SI functio We are aware that, on the basis of your further re-evaluation of the SI system electrical design, you performed analyses after discovery of the single failure problem which indicate that only one of the three SI pumps may be needed to meet the ECCS requirements of 10 CFR 50.46. This notwithstanding, the fact remains that your earlier evaluation of the SI system failed to identify several 8806300155 880615 PDR ADOCK 05000261 DCD
Carolina Power and Light Company-2 -JUN15 1988 single failures that would leave the plant in an unanalyzed condition with only one SI pump being operable. The NRC considers the previous plant operation with potentially only one SI pump operable rather than two pumps to be a significant reduction in the margin of safet To emphasize the importance of proper evaluation of ECCS system, 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 violation 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 (1988) (Enforcement Policy), the violation described in the enclosed Notice has been categorized at Severity Level II The base value of a civil penalty for a Severity Level III violation is $50,000. The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriat We understand that you are developing a design basis reconstitution program, the purpose of which is to verify the accuracy of the plant design basis, and that this action is being taken in view of the several design deficiencies identified during the Safety System Functional Inspection (SSFI) conducted by the NRC in April 1987. The significance of the enclosed violation and those design deficiencies identified during the SSFI serves to highlight the need for this program, and we encourage you to place priority on its timely completio You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your 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 requirement 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 Vi J. NELSON GRAQE J. Nelson Grace Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
AG. P. Beatty, Jr., Vice President
, Robinson Nuclear Project Department
/R. E. Morgan, Plant General Manager
Carolina Power and Light Company
- 3 bcc w/encl:
-NRC Resident Inspector DRS Technical Assistant Document Control Desk State of South Carolina PDR LPDR-SECY-CA-JTaylor, DEDRO JNGrace, RII 4Lieberman, OE JStefano, OE-tfChandler, 0GC
'FIngram, PA TMurley, NRR Enforcement Coordinators RI/ RII, RIII RIV', RV/
-Hayes, 01-SConnelly, OIA vEJordan, AEOD EA File ES File DCS efao Grac handler berman1 ef an 4NGrace
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NOTICE OF VIOLATION AND PROPOSED IMPOSITIONFOF CIVIL PENALTY Carolina Power & Light Company Docket N H. B. Robinson Unit 2 License No. DPR-23 EA 88-88 During NRC inspections conducted on January 11 - February 10, March 7, and February 11 - March 10, 1988, a violation of NRC requirements was identifie In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.20 The violation and associated civil penalty are set forth below:
10 CFR 50.46 (a) (1) requires that emergency core cooling system (ECCS)
cooling performance be calculated in accordance with an acceptable evaluation mode CFR Part 50, Appendix K sets forth standards for an acceptable mode Appendix K, Section D.1, "Single Failure Criterion" requires that in the accident evaluation the combination of ECCS subsystems assumed to be operative be those available after the most damaging single failure of ECCS equipment has taken plac Contrary to the above, as of January 29, 1988, the combination of ECCS subsystems assumed to be operative in the evaluation model in the H. B. Robinson Undated Safety Analysis Report (USAR) did not reflect certain more damaging single failures of ECCS equipment, particularly the Safety Injection (SI) system. Certain single failures could have rendered two of the three SI pumps inoperable while the H. B. Robinson USAR evaluation model assumed at most one SI pump being inoperable after the most damaging single failure. The four scenarios in which the SI safety function could have been lost only leaving one SI pump operable are (1) a single failure of the sequencer relay in the safeguard sequencing logic, (2) a single failure of the emergency diesel generator (EDG) field flash circuit after loss of offsite power and loss-of-coolant conditions, (3) a single failure of the DC control power during safeguard sequencing, and (4) a single active failure in the EDG system control This is a Severity Level III violation (Supplement I).
Civil Penalty -
$50,000 oc Pursuant to the provisions of 10 CFR 2.201, Carolina Power & Light Company
(licensee) is hereby required to submit a written statement or explanation to ONO the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a
"Reply to a Notice of Violation" and should include for each violation:
oa (1)
admission or denial of the alleged violation, (2) the reasons for the OIC violation if admitted, (3) the corrective steps that have been taken and the
results achieved, (4) the corrective steps which will be taken to avoid further CO violations, and (5) the date when full compliance will be achieved. If an OLO. adequate reply is not received within.the time specified in this Notice, an order may be issued to show cause why the license should not be modified,
- 2 suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmatio Within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to.the Treasurer of the United States in the amount of the civil penalty proposed above or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalt In requesting mitigation of the proposed penalty, the five factors addressed Section V.B of 10 CFR Part 2, Appendix C, (1988) should be addressed. Any
. written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the licensee is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalt Upon failure to pay the penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 228 The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation), should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region II, and a copy to the NRC Inspector at the H. B. Robinson Plan FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY, J. NELSON GP^!
J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia thisIS5A day of June 1988