ML14175B489
| ML14175B489 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/13/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14175B490 | List: |
| References | |
| EA-87-124, NUDOCS 8711200316 | |
| Download: ML14175B489 (4) | |
See also: IR 05000261/1987006
Text
'13 1987
Docket No. 50-261
License No. DPR-23
Carolina Power and Light Company
ATTN:
Mr. E. E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P. 0. Box 1551
Raleigh, NC
27602.
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION REPORT NOS. 50-261/87-06 AND 50-261/87-17)
This refers to a Safety System Functional Inspection (SSFI) conducted March 9
April 15, 1987, and a followup inspection conducted May 26-29, 1987, at the
H. B. Robinson Nuclear Plant, Hartsville, South Carolina. The inspection was
.
conducted to provide an in-depth assessment of the operational readiness of the
emergency power systems including the emergency diesel generators and the safe
shutdown power sources.
As a result of the inspections, certain of your
activities appeared to be in violation of NRC requirements.
Inspection Report
No. 50-261/87-06 was sent to you by letter dated June
18, 1987, and Inspection
Report No. 50-261/87-17 was sent to you by letter on July 15, 1987. On June 26,
1987, an Enforcement Conference was held with you and members of your staff in
the Region II office.
Violation I in the enclosed Notice of Violation and Proposed Imposition of
Civil Penalty (Notice) involves the failure to satisfy certain fire protection
requirements set forth in 10 CFR Part 50, Appendix R. This violation concerns
the failure to adequately establish and implement procedures for the conduct of
safe shutdown evolutions in the event of a fire.
The original procedures and training associated with dedicated/alternate
shutdown capability were developed and/or conducted by a contractor. The SSFI
revealed that the validation process and training associated with these pro
cedures were inadequate. The training, which contained less than an hour of
in-plant training on the 12 procedures, was completed using draft procedures
and did not include procedure walkthroughs. In addition, once the respon
sibility for this area was turned over to the operations department, the level
of attention devoted to preparation for implementing the dedicated shutdown
capability and the associated training, procedures, and communications apparently
decreased to an unacceptable level.
There had been no requalification training,
no walkthroughs of procedures or drills, and no additional validation or
8711200316 871113
ADOCK 05000261
Carolina Power and Light Company
- 2 -NOV
3 1987
revisions of the dedicated shutdown procedures for over 21 months.
NRC licensed
operators and supervisors stated to our inspectors that they had never walked
through the procedures and were unfamiliar with their contents and required
actions.
We are concerned with the management controls that allowed this apparent lack
of attention to fire protection requirements to occur. When licensed operators
and senior operators could not quickly locate necessary valves and breakers,
even to the point of entering the wrong rooms or buildings, and could not ade
quately communicate by radio under controlled, well-lighted conditions, it was
unlikely that they could have promptly accomplished the complex multiple local
operations necessary for the safe shutdown of the plant under severe fire and
loss of power conditions. These deficiencies were pointed out to you follow
ing the inspection conducted on March 9-April 15, 1987. After you made subse
quent commitments to immediately upgrade training and procedures, the followup
inspection on May 26-29, 1987, revealed that significant deficiencies continued
in operator training and the ability to accomplish dedicated shutdown capability.
Although these deficiencies were corrected prior to plant criticality on June 11,
1987, management attention must remain focused in the areas of development and
implementation of procedures following modification to prevent these types of
deficiencies from recurring.
To emphasize the need to assure the appropriate development and implementation
.
of procedures following plant modifications and the importance of fire protection
programs and the safe shutdown capability in the event of a fire, 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 Section I of the
enclosed Notice. In accordance with the "General Statement of Policy and Proce
dure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987) (Enforcement
Policy), the violation in the enclosed Notice has been categorized as a Severity
Level III.
The base civil penalty for a Severity Level III violation or problem
is $50,000. While your prior performance in the areas of operations and fire
protection has been good, it is offset by the inadequate corrective action
taken to upgrade the operators' familiarity with the Dedicated Shutdown Proce
dures following the March inspection. Therefore, no adjustment in the civil
penalty has been deemed appropriate.
Violation II involves inadequacies in the emergency lighting units in several
plant areas.
These inadequacies included missing or improperly directed lights
and a large number of emergency lighting units out of service because of
maintenance activities. This violation has been categorized as a Severity
Level IV violation.
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, you should address whether similar
Carolina Power and Light Company
- 3 -
N
3
procedure development and implementation issues exist in other discipline areas
as a result of plant modifications. 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.
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 Room.
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, PL. No.96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely,
ORIGINAL SIGNED RYi
J. NELSON GRACE
J. Nelson Grace
Regional Administrator
Enclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
cc w/encl:
G. P. Beatty, Jr., Vice President
Robinson Nuclear Project Department
R. E. Morgan, Plant General Manager
Carolina Power and Light Company
4
DISTRIBUTION:
NRC Resident Inspector
Document Control Desk
State of South Carolina
SECY
CA
J. Taylor, DEDO
T. Martin, DEDRO
J. Goldberg
J.Lie-berman, OE
P. Milano, OE
J. N. Grace, RII
Enforcement Coordinators
RI, RII, RIII, RIV, RV
T. Murley, NRR
B. Hayes, 01
S. Connelly, OIA
E. Jordan, AEOD
F. Ingram, PA
G. Johnson, RM
R
RiI
R I
RII
AFGibson
LReyes
GRJenkns
Ernst
11/jV/87
11/V/87
11/13/87
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