IR 05000261/1994016
| ML14181A583 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/30/1994 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14181A584 | List: |
| References | |
| EA-94-119, NUDOCS 9409070131 | |
| Download: ML14181A583 (8) | |
Text
17-I " t.Jrl I
(NUDOCS OFFSITE FACILIT)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9409070131 DOC.DATE: 94/08/30 NOTARIZED: NO DOCKET #
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~ACIL:50-261 H.B. Robinson Plant, Unit 2, Carolina Power & Light C 05000261 AUTH.NAME AUTHOR AFFILIATION BNETER, Region 2 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION HINNANT, Carolina Power & Light C P SUBJECT: Discusses insp rept 50-261/94-16 on 940522-0624 & forwards notice of violation & proposed imposition of civil penalt Violation involves failure to implement adequate design reviews & suitable testing program DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:7 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response
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E NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P1-37 (EXT 504-2083 ) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR
ENCL
Docket N License No. DPR-23 EA 94-119 Carolina Power & Light Company ATTN:
Mr. C. S. Hinnant Vice President H. B. Robinson Steam Electric Plant, Unit 2 Post Office Box 790 Hartsville, South Carolina 29551-0790 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$75,000 (NRC Inspection Report No. 50-261/94-16)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by Mr. William T. Orders on May 22 through June 24, 1994, at the H. B. Robinson Steam Electric Plant, Unit 2. The inspection included a review of a design deficiency in the control room ventilation system (CRVS)..
This deficiency was reported in Licensee Event Report 261/94-008 in accordance with 10 CFR 50.73(a)(2)(ii).
As a result of the NRC inspection, violations of NRC regulatory requirements were identified. The report documenting the NRC inspection was sent to you by letter dated July 11, 199 An enforcement conference was conducted in the NRC Region II office on July 26, 1994, to discuss the violations, their cause, and your corrective actions to preclude recurrence. A summary of this conference was sent to you by letter dated August 5, 199 The violation described in Part I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involves the failure to implement adequate design reviews and suitable testing programs to verify that the CRVS was capable of performing its intended safety function. The facts and circumstances concerning this violation are fully discussed in the referenced inspection report and were also discussed during the July 26, 1994 enforcement conferenc Your analysis of the safety consequences of an increase in radiation levels in the control room due to the introduction of contaminated air from adjacent areas concluded that the control room radiation exposure limits specified by General Design Criterion 19 would have been exceeded in approximately one hour if the operators did not take action to secure the supply fan affecting adjacent areas. Although the control room operators would have been alerted to an increase in radiation levels by area radiation monitors, no procedures were in place to ensure that the supply fan was secure With regard to Violation I, the NRC is concerned that your engineering design reviews failed to consider how different configurations of ventilation system operation in areas adjacent to the control room could effect the operation of 9409070131 940830 PDR ADOCK 05000261 G
August 3u, 1994 Carolina Power and-2 Light Company the CRVS in the emergency pressurization mode of operation. The design requirements of the CRVS are clearly defined in Sections 6.4 and 9.4.2 of the Updated Final Safety Analysis Report (UFSAR).
Sections 6.4 and 9.4.2 of the UFSAR require that the control room be maintained at a positive differential pressure with respect to adjacent areas during the CRVS emergency pressuriza tion mode of operation. The NRC is also concerned that your CRVS testing failed to: (1) incorporate measurements of the pressure in adjacent rooms; (2)
compare these pressures to the control room pressure during testing of the CRVS emergency pressurization mode of operation; and, (3) include appropriate acceptance criteria for testing control room pressures with respect to the atmospheric pressure outdoors. When an NRC inspector questioned the adequacy of the CRVS testing, you discovered, through subsequent testing, that measures were not in place to ensure that one of the safety functions of the CRVS, i.e., to maintain a positive pressure in the control room with respect to adjacent areas, was met. Specifically, if a supply fan was running in an adjacent area with the exhaust fan secured, the pressure in the adjacent area could-exceed the control room pressure thus allowing air contaminated during an event to enter the control roo Failure to meet the intended safety function was evidenced when, on May 7, 1994, testing revealed that a positive pressure relative to the control room existed in Reactor Auxiliary Building (RAB) room E1/E2 with the room E1/E2 supply fan, fan HVE-1, running and the RAB exhaust fan, HVE-7, secured. Therefore, in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, this violation has been categorized at Severity Level II The NRC recognizes that specific corrective actions were taken in response to the violation as discussed during the enforcement conference. Those actions included (1) revision of the emergency operating procedures in regard to the CRVS operation to ensure that the RAB supply fan is secured in the event of an accident condition; (2) revision to the testing procedure to specify appropriate initial conditions and acceptance criteria; and (3) review of a sample of other modifications to ensure the adequacy of the surveillance test initial conditions and testing methods, and to confirm that possible adverse interactions with other systems have been identifie To emphasize the importance of ensuring control over design and testing activities affecting safe plant operations, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the amount of $75,000 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 considere Escalation of 50 percent was applied for the factor of identification because the violation was discovered as a result of an NRC inspection of testing of the CRVS. Escalation of 50 percent was also applied for the factor of duration because of the length of time, from early 1991 until the problem was corrected in May 1994, that the CRVS was unable to meet its intended safety function. Mitigation of 50 percent was warranted for the
August 30, 1994
Carolina Power and
- 3 Light Company factor of corrective action because after the violation was identified, good corrective actions were taken. The other factors in the Enforcement Policy were considered but no further adjustments were warranted. Therefore, the adjusted civil penalty is $75,00 The violations described in Part II of the Notice both involved the failure to ensure that conditions adverse to quality are promptly identified and corrected. Violation II.A involved the failure to isolate a non-safety related system from the safety-related main steam isolation valves (MSIVs)
during periodic testing of the valves at no-load, hot conditions. This deficiency was reported in LER 261/94-002 in accordance with 10 CFR 50.73(a)(2)(i). Specifically, provisions were not implemented to verify that the MSIVs were capable of closing in the TS required time (five seconds) and remaining closed when instrument air, a non-safety-related system, was isolated from the valve actuators during no-load (hot conditions).
The MSIVs had been tested in this fashion (instrument air not isolated from the valve actuator) since the plant was originally licensed despite your identification of this condition adverse to quality in your March 8, 1985 response to a violation issued in NRC Inspection Report 84-44, dated February 6, 1985. Your response indicated that under certain accident situations, isolation of the steam generators could not be assured, relying solely on instrument air. The temporary modification discussed in your response, which added a nitrogen backup to ensure operation of the MSIV actuators, was subsequently removed without revisions to the test criteria to ensure that the MSIVs would close and remain closed With non-safety-related instrument air isolated. In addition, NRC Information Notice 85-84 was issued on October 30, 1985 to inform licensees of problems associated with the testing of safety-related components that are supported by non-safety-related systems. While we acknowledge your position that the minimum design requirements were met for the closure time of the MSIVs, the design was marginal when the effect of isolating the non-safety-related instrument air system was considere Violation II.B involved the failure to provide adequate management oversight of the disposition of findings of a contractor's assessment of compliance with technical specification (TS) Table 4.1-1, Minimum Frequencies for Checks, Calibrations and Test of Instrument Channels. This deficiency was reported in LER 261/94-001 in accordance with 10 CFR 50.73(a)(2)(i). The contractor's findings were documented in a June 30, 1992 report to you; however, corrective actions in response to the findings were not promptly defined and brought to closure. This resulted in the failure to correct conditions adverse to quality in regard to testing of the 4 KV undervoltage trip and calibration of the Overpressure Protection System. These conditions had existed since issuance of the operating license. In addition, your failure to act on findings concerning potential deficiencies in the implementation of other TS requirements, led to the failure to promptly identify that the setting for the High Steam Flow in 2/3 Steam Lines instrumentation was higher than the setting required by TS Table 3.5-.
The NRC is concerned that a common root cause of Violations I, II.A and I is your failure to conduct adequate engineering design reviews and to ensure
Carolina Power and
- 4 Light Company that adequate testing programs were developed to verify safety functions of safety-related equipmen Each of the violations represent long-standing design and testing deficiencies. The NRC is also concerned that the findings of a self-assessment initiated by the Plant Nuclear Safety Committee were not resolved in a timely manner and did not receive an appropriate level of management attention. If these matters are not promptly corrected, they could lead to a more significant regulatory concer 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 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 Room (PDR).
Accordingly, your response should not to the extent possible, include any personal privacy, proprietary, or safeguards information so that it can be released to the public and placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate
).
the specific information that you believe should not be placed in the PDR, and provide the legal basis to support your request for withholding the information from the publi 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 Should you have any questions concerning this letter, please contact u
Sincerely, (Original signed by S. Ebneter)
Stewart D. Ebneter Regional Administrator Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
See Next Page SEND OFC RII:DRP RII:DRP A
RII:DRS RI EICS RII:ORA RII:ORA TO/-/C
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I NAME HChr nsen Bo AGibson CE s
LReyes YES DATE 08/ 2-OV94 08/A /94 08/-z94 08v
/94 08/Z7/94 08/
/94 NO COPY?
No Yes No Yes ) No Yes No es No OFFICIAL RECORD OPY DOCUMElT NAME H1\\94119R0B.DIR\\FlI GND.SDE
August 30, 1994 Carolina Power and-5 Light Company cc w/encl:
M. P. Pearson H. Ray Starling Plant Manager Manager -
Legal Department H. B. Robinson Steam Electric Plant Carolina Power and Light C P. 0. Box 790 P. 0. Box 1551 Hartsville, SC 29550 Raleigh, NC 27602 H. W. Habermeyer, J Karen E. Long Vice President Assistant Attorney General Nuclear Services Department State of North Carolina Carolina Power & Light Company P. 0. Box 629 P. 0. Box 1551
- Mail 0HS7 Raleigh, NC 27602 Raleigh, NC 27602 Robert P. Gruber R. Krich, Manager Executive Director Regulatory Compliance Public Staff -
NCUC H. B. Robinson Steam Electric Plant P. 0. Box 29520 P. 0. Box 790 Raleigh, NC 27626-0520 Hartsville, SC 29550 Public Service Commission Max Batavia, Chief State of South Carolina Bureau of Radiological Health P. 0. Box 11649 Dept. of Health and Environmental Columbia, SC 29211 Control 2600 Bull Street Hartsville Memorial Library Columbia, SC 29201 147 W. College Hartsville, SC 29550 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environmental Commerce & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 RoetP.Gue
FROM 0S.25.1994 14:16 Carolina Power &
Light Company SECY CA JTaylor, EDO JMilhoan, DEDR SEbneter, RI!
JLieberman, OE JGray, OE MlSatorius, OE JGoldberg, OGC RZimmerman, NRR WRussell, NRR Enforcement Coordinators RI, RII, RIIi, RIV JFitzgerald, 01 EJordan, AEOD DWilliams, 0IG EA File (2)
MSatorius, OE NUDOCS DMatthews, NRR AGibson, RI1 HChristensen, RI!
JStarefos, RI!
BMozafari, NRR KClark, RI!
BUryc, RI1 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route S. Box 413 Hartsville, SC 29551 OE A:RII D:0 Be-'r JL e>
man 82 94 08 2'94
94 Doc Name: G:\\0ECASES\\94119RTII3B
- END***
Carolina Power and Light Company DISTRIBUTION PDR SECY CA JTaylor, EDO JMilhoan, DEDR SEbneter, RH JLieberman, OE JGray, OE MSatorius, OE JGoldberg, OGC RZimmerman, NRR WRussell, NRR Enforcement Coordinators RI, RII, RIII, RIV JFitzgerald, 01 EJordan, AEOD DWilliams, OIG EA File (2)
MSatorius, OE NUDOCS DMatthews, NRR AGibson, RII HChristensen, RII JStarefos, RII BMozafari, NRR KClark, RII BUryc, RIH NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 5, Box 41 Hartsville, SC 29551