ML14181A854

Notice of Violation from Insp on 960928-1116.Violation Noted:On 961016,operations Surveillance Test Procedure OST-160 Pressure Isolation Check Valve Back Leakage Test, Rev 23,inadequate,did Not Provide Adequate Instructions

ML14181A854
Person / Time
Site:	Robinson
Issue date:	12/16/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14181A853	List: ML14181A854 ML14181A855
References
50-261-96-12, NUDOCS 9612230320
Download: ML14181A854 (3)

Text

NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-261 H. B. Robinson Unit 2 License No. DPR-23 During an NRC inspection conducted from September 29 through November 16, 1996, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG-1600, the violations are listed below:

A.

Technical Specification 6.5.1.1.1, Procedures, Tests, and Experiments, states that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978, including procedures for leak testing reactor coolant system (RCS) pressure isolation valves.

Contrary to the above, on October 16, 1996, Operations Surveillance Test (OST) procedure OST-160, Pressure Isolation Check Valve Back Leakage Test, Revision 23, was inadequate in that it did not provide adequate instructions for configuring test apparatus (i.e., loop seal for a specific drain hose), resulting in a water hammer in the Safety Injection Cold Leg Injection lines during test restoration actions.

This is a Severity Level IV violation (Supplement I).

B.

10 CFR 50, Appendix B, Criterion XI, Test Control, specifies requirements for testing performed to demonstrate that components will perform satisfactorily in service. This criterion requires that test results shall be documented and evaluated to assure that test requirements have been satisfied.

Contrary to the above, licensee evaluations of the results of the Motor Operated Valve (MOV) tests did not assure that test requirements had been satisfied, in that:

(1) The licensee's evaluation (documented in Calculation RNP-M/MECH 1473, Rev. 0) of the results of a dynamic test performed on valve SI-870A failed to identify that the intended differential pressure and flow may not have been produced. Diagnostic trace and downstream pressure data indicated appropriate test conditions were not achieved. Data for tests performed for MOVs MS-V1-8B and FP-248 indicated similar deficiencies.

(2) The licensee's evaluations of MOV opening diagnostic test results failed to consider measurement equipment uncertainty. This uncertainty was described in Customer Service Bulletin 31 issued by the vendor of the licensee's VOTES diagnostic equipment.

9612230320 961216 PDR ADOCK 05000261 G

PDR

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(3) The licensee's evaluation of the dynamic test results for opening valve MS-V1-8B failed to establish whether an anomaly in the force measurements resulted in invalid test results. This anomaly was documented in Calculation RNP-M/MECH-1406, Rev. 1.

This is a Severity Level IV violation (Supplement I).

C.

10 CFR 50, Appendix B, Criterion III, Design Control, requires measures which assure that the applicable regulatory requirements and design basis for safety-related components are correctly translated into specifications, drawings, procedures, and instructions. When this translation is accomplished through calculations, the measures must assure that the assumptions and data used in performing the calculations are justified and correct.

Contrary to the above, the licensee's measures did not assure that the applicable regulatory requirements and design basis for safety-related components would be correctly translated into specifications, drawings, procedures, and instructions. Calculations which the licensee used to determine the settings to be specified for MOVs to perform their design basis functions used unjustified assumptions and incorrect data inputs, as follows:

(1) The licensee did not adequately justify the valve factors, rate of loading and stem friction coefficients, (VF, ROL, and SFC) that were assumed for calculating settings for MOVs that did not have satisfactory dynamic tests. The licensee had no documented evaluation or analysis which demonstrated that the values used were applicable to the Robinson MOVs.

(2) The valve factor calculations for opening valves such as MS-V1-8B, AFW-V2-14A, FP-248, and SI-880D, incorrectly accounted for the MOV stem rejection force. The stem rejection load used in the calculation was obtained from dynamic data taken after the system pressure and, therefore, the rejection force had decreased.

This is a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or

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include previous docketed correspondence, if the correspondence adequately addresses the required response. 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. Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be 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 desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Atlanta, Georgia this 16th day of December 1996