ML14178A181
| ML14178A181 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/16/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14178A180 | List: |
| References | |
| EA-91-142, NUDOCS 9201280142 | |
| Download: ML14178A181 (3) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Carolina Power and Light Company Docket No. 50-261 H. B. Robinson Nuclear Plant License No. DPR-23 EA 91-142 During an NRC inspection conducted on September 27 -
October 11, 1991, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), 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 2.205. The particular violation and associated civil penalty are set forth below:
10 CFR 50, Appendix B, Criterion III, requires, in part, that measures be established for the identification and control of design interfaces and for coordination among participating design organizations. Criterion III also requires that design control measures provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
Contrary to the above, inadequate control of design interfaces and coordination among participating design organizations resulted in the failure to adequately verify or check the adequacy of design for the Safety Injection (SI) system and the Reactor Protection System (RPS),-as evidenced by the following examples:
- 1. From June 20, 1988 until January 5, 1989, a design basis analysis was not developed for single SI pump operation during the time interval for Emergency Core Cooling System (ECCS) transfer from the injection phase to the recirculation phase (switchover) during a large break Loss of Coolant Accident (LOCA).
- 2.
From January 5, 1989 until May 16, 1991, a design activity analysis (Nuclear Fuels Section Design Activity 89-0001) to support single SI pump operation during a large break LOCA was inadequate in that losses of Reactor Coolant System inventory due to entrainment were not properly considered.
- 3.
From June 20, 1988 until August 3, 1991, a design basis analysis was not developed for single SI pump operation during the time interval for ECCS switchover during a small break LOCA.
- 4. The Resistance Temperature Detector Bypass Removal Modification, M-959, was inadequately developed, verified, and performed in that from February 25, 1989 until August 17, 1991,.the Overtemperature Delta Temperature reactor trip time response exceeded the time used in the accident analysis.
This is a Severity Level III violation (Supplement 1).
Civil Penalty -
$37,500 9201260142 911216 PDR ADOCK 05000261 G
-2 Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation:
(1) admis sion or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, 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 affirmation.
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, money order, or electronic transfer 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 in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1991), 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 penalty.
Upon failure to pay any civil penalty due which subsequently has been 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. 2282(c).
- 3 The response noted above (Reply to 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, Regi6n II,,and a copy to the NRC Resident Inspector at the H. B. Robinson facility.
Dated at Atlanta, Georgia thisj44d day of December 1991