IR 05000261/1991020
| ML14178A179 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/16/1991 |
| From: | Ebneter S NRC/IE, NRC/RGN-II |
| To: | Eury L Carolina Power & Light Co |
| Shared Package | |
| ML14178A180 | List: |
| References | |
| EA-91-142, NUDOCS 9201280135 | |
| Download: ML14178A179 (7) | |
Text
DEC16 1W91 9YA~
2 A7: 4 Docket No. 50-261 License No. DPR-23 EA 91-142 Carolina Power and Light Company ATTN:
Mr. Lynn W. Eury Executive Vice President Power Supply Post Office Box 1551 Raleigh, North Carolina 27602 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$37,500 (NRC INSPECTION REPORT NO. 50-261/91-20)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by Mr. L. Garner on*September 27 - October 11, 1991, at the H. B. Robinson Nuclear Plant. This inspection included an examination of the facts related to several recently identified examples of inadequate engineering design control and interfaces associated with modifications to the Safety Injection System and the Reactor Protection System. The report documenting this inspection was sent to you by letter dated October 25, 1991. As a result of this inspection, a violation of NRC requirements was identifie An enforcement conference was held on November 6, 1991, in the NRC Region II office to discuss the violation, its cause, and your corrective actions to preclude recurrence. A summary of this conference was sent to you by letter dated November 15, 199 The violation in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved four examples which indicated significant inadequacies in engineering design control, as well as engineering interfaces and coordination with other organization Examples 1 through 3 in the enclosed Notice involved the development.of revisions to the design basis analysis for the Safety Injection (SI) system. Specifically, your staff failed to properly analyze single SI pump operation during the time interval in which Emergency Core Cooling System (ECCS) is transferred from the injection mode to the recirculation mode following a loss of coolant accident (LOCA). Addi tionally, on separate occasions your staff failed to consider the effects of entrainment inventory loss during ECCS transfer and failed to evaluate the significance of entrainment inventory loss for a large break LOC These examples reflect inadequate reviews and analyses, as well as inadequate management control and oversight. Such weaknesses resulted in the failure to perform an adequate analysis to support single SI pump operation in June 198 when an amendment to Technical Specifications was submitted to the NRC to 9201280135 911216 PDR ADOCK 05000261
Carolina Power and Light Company-2-DEC 16 1891 support this mode of operation; a subsequent inadequate design activity analysis (Nuclear Fuels Section Design Activity 89-0001) performed in January 1989; the use of an improper decay heat model on May 14, 1991, as a basis for power ascension,;
and a complete small break LOCA analysis not being performed because of an assumption that the lar'ge break LOCA analysis -was more limitin Example 4 of the violation involved a problem with the time delay function in the Resistance Temperature Detector (RTD) system that was caused by capacitors not being removed from the Overtemperature Delta Temperature (OT Delta T) and Overpressure Delta Temperature (OP Delta T) Reactor Protection System (RPS)
circuitry during the RTD Bypass Removal Modification (M-959) completed in February 1989. As a result, the OT Delta T.protection circuitry response time exceeded that used in transient analyses by up to approximately two second The vendor who prepared the modification failed to specifically include capacitor removal in the related modification guidelines and provide a post modification transient test of the associated circuitry. Your staff's engineering reviews performed on the modification guidelines, as well as subsequent modification development and reviews, failed to identify the fact that the capacitors needed to be removed. Reliance on the vendor work not withstanding, the problem of inadequate engineering design control and interfaces is also evidenced by this example of the violatio The above examples of identified inadequacies in engineering design control and interfaces, as well as their potential impact on the safe operation of plant systems are a significant safety concern. Therefore, in accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions,"
.(Enforcement Policy) 10 CFR Part 2, Appendix C (1991), this violation has been categorized at Severity Level II The NRC recognizes that three of these examples were identified by your staff and that prompt and appropriate corrective actions were taken, including unit shutdown for the OT Delta T capacitor issu To emphasize the importance of ensuring that engineering design control and interfaces are fully functional in all required aspects of design change review, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $37,500 for the Severity Level III violation. The base value of a civil penalty for a Severity Level III violation is $50,00 The escalation and mitigation factors in the Enforcement Policy were considered and mitigation of the base civil penalty by 50 percent was warranted for identification and reporting because three of the examples cited in the violation were identified by your staff. Neither escalation nor mitigation was warranted for corrective action. While appropriate immediate actions, which included in one case bringing the unit to shutdown, were taken, they were offset by the lack of long-term corrective action such as the management control enhancements which you described at the enforcement conference that
O!C 11991 Carolina Power and Light Company-3 have yet to be fully effective. For example, during the enforcement conference, your staff discussed management efforts that have been ongoing for a couple of years to instill ownership of vendor products, reinforce responsibility for vendor designs, and ensure engineering work was assigned to staff members with appropriate training and expertise. However, despite such efforts, an improper decay heat model was used to justify operation at 95 percent power following the discovery of the improper ECCS analysis in May 199 Neither escalation nor mitigation was warranted for past performance due to previous escalated enforcement action (EA 89-188) in November 1989 that involved the operation of the auxiliary feedwater system in a degraded condition. This previous enforcement action, which also involved the failure to identify and correct critical engineering issues, offset consideration for mitigation based on your more recent generally.improving performance. Escalation of 25 percent was warranted for prior notice of similar events because the 1987 vendor analysis that addressed the entrainment phenomena should have alerted your staff to Example 2 of the Notice. The factor of multiple occurrences was used in categorizing this violation at Severity Level II The other adjustment factors in the Enforcement Policy were considered and no further adjustment to the base civil penalty was considered appropriate. Therefore, based on the above, the base civil penalty has been decreased by 25 percen 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. In addition, during the enforcement conference it came to our attention that you may have assumed the availability of non-Technical Specification equipment to mitigate the consequences of accidents addressed in Chapter_ 15 of the Updated Final Safety Analysis Repor Consequently, as part of your response to this enforcement action, you are also requested to address any such assumptions that may have been made in Chapter 15 analyses. Following receipt of your response, should any additional information on this issue be necessary, it will be addressed separately from the enclosed enforcement action. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspec tions, the NRC will determine whether further NRC enforcement action is neces sary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," 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 )
Carolina Power and Light Company-4-DEC 18 1991 Should you have any questions concerning this letter, please contact u
Sincerely, OigginA Sgn1ed By 1. L Mihoan Stewart D. Ebneter Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
C. R. Dietz, Manager Robinson Nuclear Project Department H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 Carolina Power and Light Company J. J. Sheppard, Plant General Manager O
H H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 Heyward G. Shealy, Chief Bureau of Radiological Health Dept. of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 McCuen Morrell, Chairman Darlington County Board of Supervisors County Courthouse Darlington, SC 29535 Richard E. Jones, General Counsel Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 cc w/encl cont'd:
(see next page)
Carolina Power and Light Company
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5 -
- 1091 cc w/encl cont'd:
H. A. Cole Special Deputy Attorney General State of North Carolina P. 0. Box 629 Raleigh, NC 27602 Robert Gruber Executive Director Public Staff - NCUC P. 0. Box 29520 Raleigh, NC 27626-0520 J. D. Kloosterman, Director Regulatory Compliance H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 State of North Carolina
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Carolina Power and Light Company
DEC 1 DISTRIBUTION:
PDR SECY CA JTaylor, EDO JSniezek, DEDR SEbneter, RII JLieberman, OE JLuehman, OE JGoldberg, OGC FIngram, PA/GPA Enforcement Coordinators RI, RII, RIII, RIV, RV BHayes, 01 EJordan, AEOD JPartlow, NRR NRR Project Manager, NRR DWilliams, OIG EA File OE Day File DCS JJocument Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 RI RI RII schoff CFEv GR/en ns can
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Carolina Power and Light Company DEC 1 6 1991 DISTRIBUTION:
PDR SECY CA JTaylor EDO JSnieze, DEDR SEbneter, RII OLieberman, OE 3Luehman, OE JGoldberg, CGC Flngram, PA/SPA Enforcement Coordinators RI, RI, R!!!, RIV, RV 8Hayes, 01 EJordan, AEOD JPartlow, NRR NRR Project Manager, NRR DWilliams, 0IG EA File OE Day File DCS NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 5 Box 413 Hartsville, SC 29550 JL an SEb J
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