ML14181A762
| ML14181A762 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/20/1995 |
| From: | Merschoff E NRC/RGN-II, NRC/IE |
| To: | Hinnant C Carolina Power & Light Co |
| References | |
| NUDOCS 9509280198 | |
| Download: ML14181A762 (6) | |
See also: IR 05000261/1995014
Text
September 20, 1995
Carolina Power & Light Company
ATTN:
Mr. C. S. Hinnant
Vice President
H. B. Robinson Steam Electric Plant
Unit 2
3581 West Entrance Road
Hartsville, SC 29550
SUBJECT:
NRC INSPECTION REPORT NO. 50-261/95-14
Dear Mr. Hinnant:
Thank you for your response of July 12, 1995, to the Notice of Violation
issued on June 12, 1995, concerning activities conducted at your Robinson
facility. We have examined your response and found that it meets the
requirements of 10 CFR 2.201.
In your response, you denied that a violation of NRC requirements occurred
with regard to Violation A which concerns three examples of inadequate
measures established to ensure the quality of purchased services. You agree
.
that Violation B occurred as described.
After careful consideration of the bases for your denial of the violation, we
have concluded, for reasons presented in the enclosure to this letter, that
Violation A occurred as described. Therefore, in accordance with
10 CFR 2.201(a), please submit to this office within 30 days of the date of
this letter a written statement describing steps which have been taken to.
correct Violation A and the results achieved, corrective steps which will be
taken to avoid further violations, and the date when full compliance will be
achieved.
We will examine the implementation of your actions to correct Violation B
during future inspections.
The response directed by this letter is 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.96-511.
We appreciate your cooperation in this matter.
Sincerely,
9509280198 950920
ADOCK 05000261
Ellis
Merscoff, Director
Q
Division of Reictor Projects
Docket No.: 50-261
License No.:
Enclosure:
(See page 2)
2
Enclosure: Evaluations and Conclusion
cc w/encl:
Dale E. Young
Plant Manager
H. B. Robinson Steam Electric Plant
3581 West Entrance Road
Hartsville, SC
29550
H. W. Habermeyer, Jr.
Vice President
Nuclear Services Department
Carolina Power & Light Company
P. 0. Box 1551
- Mail OHS7
Raleigh, NC 27602
R. M. Krich, Manager
Regulatory Affairs
H. B. Robinson Steam Electric Plant
3581 West Entrance Road
Hartsville, SC 29550
Max Batavia, 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 Environmental
Commerce & Natural Resources
P. 0. Box 27687
Raleigh, NC
27611-7687
R. E. Jones
General Counsel - Legal Department
Carolina Power & Light Co.
P. 0. Box 1551
Raleigh, NC 27602
Karen E. Long
Assistant Attorney General
State of North Carolina
P. 0. Box 629
Raleigh, NC 27602
(cc w/encl cont'd - See page 3)
S
3
(cc w/encl cont'd)
Robert P. Gruber
Executive Director
Public Staff -
NCUC
P. 0. Box 29520
Raleigh, NC
27626-0520
Public Service Commission
State of South Carolina
P. 0. Box 11649
Columbia, SC
29211
Hartsville Memorial Library
147 W. College Avenue
Hartsville, SC 29550
Distribution w/encl:
D. Verrelli, RH
B. Mozafari, NRR
G. A. Hallstrom, RH
PUBLIC
NRC Resident Inspector
U. S. Nuclear Regulatory Commission
2112 Old Camden Road
Hartsville, SC 29550
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17
EVALUATIONS AND CONCLUSION
On June 12, 1995, a Notice of Violation (Notice) was issued for a
violation identified during a routine NRC inspection. Carolina Power &
Light Company (CP&L) responded to the Notice on July 12, 1995. CP&L
denied that a violation of NRC requirements occurred with regard to
Violation A. The NRC's evaluations and conclusion regarding the
licensee's argument are as follows:
Restatement of Violation A
10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material,
Equipment, and Services, requires in part, that measures be established
to ensure the quality of purchased services. Implicit in this
requirement are the requisites that contracted service personnel who
perform activities affecting quality, be indoctrinated and trained as
necessary to assure that they achieve and maintain a suitable
proficiency, and that they accomplish activities affecting quality in
accordance with instructions, procedures or drawings of a type
appropriate to the circumstances.
Contrary to the above, the measures established by the licensee to ensure
the quality of purchased services were inadequate in that:
1) On May 8, 1995, a contracted refueling technician failed to follow
procedure FHP-001, Fuel Handling Tools Operating Procedure,
regarding the orientation of a thimble plug tool he was using.
Ultimately, this resulted in his failure to successfully perform
nineteen steps of procedure FMP-19, Fuel And Insert Shuffle.
2) On May 3, 1995, a contracted refueling technician did not verify
polar crane/refueling manipulator crane clearance after he relocated
the latter; the contracted polar crane operator had not been trained
on Maintenance Instruction MI-510, Polar Crane General Instructions;
the contracted polar crane operator had not received a cogent
proficiency verification on the polar crane's operation; and the
polar crane operator did not verify the position of the refueling
manipulator crane before moving the polar crane. Ultimately, this
resulted in the polar crane colliding with the refueling manipulator
crane, causing significant structural damage to the latter.
3) On May 4, 1995, the contracted polar crane operator moved the polar
crane on his own initiative, with no communication or direction from
the signalman, from a position in which he could not see the
auxiliary hook. This resulted in the auxiliary hook striking the
concrete cubicle surrounding the top of the "C" steam generator.
This is a Severity Level IV violation (supplement I).
2
Summary of Licensee's Response
The licensee's response details the commitments made by CP&L to meet the
requirements of 10 CFR 50, Appendix B, Criterion VII, to ensure the
quality of purchased services. The licensee states that the training
requirements for the contractors were specified in the appropriate
contracts and were carried out. The licensee argues that the commitments
were met by the "implementation of the purchase contract requiring that
contractors meet the provisions of the CP&L QA Program, and by the
conduct of training specified in the procurement documents" and
therefore, denied the violation.
In reply to the first example of the Violation A, which involved a
contracted refueling technician who failed to follow a fuel handling
procedure, the licensee states that during the performance of procedure
FMP-019, Fuel And Insert Shuffle, the contractor failed to successfully
perform nineteen steps of the procedure when he failed to review
procedure FHP-001, Fuel Handling Tools Operating Procedure. The licensee
states that FHP-001 was a procedure that was required to be reviewed
under the provisions of their contract. In addition, the licensee states
that the cause of the event was inattention to detail by the contract
supervisor who failed to review the general precaution in procedure
FHP-001 and a failure by personnel performing procedure FMP-019 to verify
thimble plug movement during each step of the movement of the plugs.
In reply to the second example of the Violation A, which involved a
contracted technician who was neither adequately trained on, nor verified
to be proficient in, the operation of the reactor building polar crane,
the licensee concluded that the event was caused by an inadequate design
of interlocks for the polar crane system that affords no protection for
certain configurations of the polar and manipulator cranes. However, the
licensee states that the contract training requirements did not include
training on MI-510, Polar Crane General Instructions.
In the third example of the Violation A, the same polar crane operator
initiated a polar crane move of his own initiative, without being able to
see the auxiliary hook, and did not use a signalman.
NRC Evaluation
The licensee's response argues that the measures put in place to ensure
the quality of contractor services were adequate; yet, the response
admits to deficiencies in providing and implementing these measures.
In example 1 of Violation A, the contract supervisor failed to review the
general precautions of a required procedure and failed to implement
procedures. The licensee does not provide information on training of
contractors in CP&L's expectations on procedure compliance and
supervision of work. In this case, although we agree that the fact that
procedure FMP-019 did not reference FHP-001 or contain information about
ENCLOSURE
3
thimble orientation is a weakness; we conclude that deficiencies existed
in the training and knowledge of the contract supervisor in that the
provisions of the contract were not met for review of a required
procedure and no argument is presented that CP&L is ensuring appropriate
training on procedural compliance and work supervision.
The NRC does agree with your assessment of the second example of the
violation. Although an interlock system could be an effective deterent
to inappropriate movement of the polar crane, it should not be relied
upon as a substitute for procedure implementation and adequate
training/indoctrination. In this specific case, had the contract
required training of the polar crane operator on procedure MI-510, Polar
Crane General Instructions, which specifically requires that the polar
crane operator verify the position of the manipulator crane before moving
the polar crane, the event may have been prevented.
The third example of violation A, where the same polar crane operator
initiated a polar crane move of his own initiative, is also indicative of
inadequate training/indoctrination, the lack of adequate procedures or
the failure to use them, and lack of supervision. This example occurred
one day after example 2 discussed above, further indicating the
deficiencies in the contract employee's training.
Even though the event
described in example 2 resulted in significant damage to the refueling
manipulator crane, the licensee does not indicate that immediate action
was taken to confirm the contract crane operator was adequately trained
for the work prior to performing additional crane manipulations.
Ultimately, the three examples were caused by a lack of adequate
contractor supervision and inadequate training. Both of these are
critical elements in a contractor control program.
NRC Conclusion
Accordingly, the NRC concludes that the violation occurred as stated.
ENCLOSURE