ML14181A989
| ML14181A989 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/04/1998 |
| From: | Reyes L NRC/IE, NRC/RGN-II |
| To: | Keenan J Carolina Power & Light Co |
| Shared Package | |
| ML14181A990 | List: |
| References | |
| 50-261-98-03, 50-261-98-3, EA-98-043, EA-98-050, EA-98-43, EA-98-50, NUDOCS 9803180028 | |
| Download: ML14181A989 (7) | |
See also: IR 05000261/1998003
Text
CATEGORY 2
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9803180028
DOC.DATE: 98/03/04 NOTARIZED: NO
DOCKET #
FACIL:50-261 H.B. Robinson Plant, Unit 2, Carolina Power & Light C
05000261
AUTH.NAME
AUTHOR AFFILIATION
REYES,L.A.
Region 2 (Post 820201)
RECIP.NAME
RECIPIENT AFFILIATION
KEENAN,J.S.
Carolina Power & Light Co.
SUBJECT: Discusses insp rept 50-261/98-03 on 980105-09 & forwards
C
DISTRIBUTION CODE: IE01D
COPIES RECEIVED:LTR _ ENCL
SIZE: 7 5/ A
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response
T
NOTES:
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PD2-1 PD
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EXTERNAL: LITCO BRYCE,J H
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE.
TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS
OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION,
CONTACT THE DOCUMENT CONTROL
DESK (DCD) ON EXTENSION 415-2083
TOTAL NUMBER OF COPIES REQUIRED: LTTR
17
ENCL
17
March 04, 1998
EA 98-043
EA 98-050
Carolina Power & Light Company
ATTN: Mr. J. S. Keenan
Vice President
H. B. Robinson Steam Electric Plant Unit 2
3581 West Entrance Road
Hartsville, South Carolina 29550
SUBJECT:
(NRC INSPECTION REPORT NO. 50-261/98-03)
Dear Mr. Keenan:
This refers to the inspection conducted on January 5-9, 1998, at the Robinson
Steam Electric Plant. The purpose of the inspection was to follow up on the
inspection findings resulting from the Nuclear Regulatory Commission's (NRC)
Design Inspection which was conducted between April 7 and May 23, 1997. The
results of the inspection were discussed with your staff in an exit interview
on January 30, 1998 and were formally transmitted to you by letter dated
February 6, 1998. An open predecisional enforcement conference was conducted
in the Region II office on February 19, 1998. to discuss the apparent
violations-.the root causes, and your corrective actions to preclude
recurrence. A list of conference attendees and copies of the NRC's
presentation material, and materials you presented at the conference are
enclosed.
Based on the information developed during the inspection and the information
you provided during the conference, the NRC has determined that violations of
NRC requirements occurred. The violations are cited in the enclosed Notice of
Violation (Notice), and the circumstances surrounding them are described in
detail in the subject inspection report.
Violation A involves the failure to verify the adequacy of a design change to
the safety injection (SI) system. The design change, Modification M-951,
which was implemented in March 1988, disabled the automatic start feature for
one of the three SI pumps. The calculation that supported the design change
did not include verification that SI pumps B and C had sufficient net positive
suction head (NPSH) in this configuration for an event involving a large break
loss of coolant accident (LOCA) and loss of one of the two remaining SI pumps
due to a single failure. As a result, the SI system design failed to meet the
operability requirements of Technical Specification (TS) 3.3.1.1.c (the TS in
effect in June 1997 when the violation was discovered).
The NPSH calculation for Modification M-951 included an incorrect assumption
that the piping configuration for SI pump A represented the most limiting
condition with regard to NPSH. As.a result, the NPSH available for pumps B
- P18002DR
F' DR
8
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P DR
2
and C under the conditions established by the 1988 modification was not
reviewed at the time of the modification nor when NPSH issues were raised in
subsequent reviews. The potential consequences of the design deficiencies
were limited, during the time of occurrence, due to the high, actual
availability and reliability of the A SI pump and the limited LOCA break size
and pump configurations necessary to create an inadequate NPSH condition.
However, given the regulatory significance and duration of this problem and
the potential impact on plant safety, Violation A has been categorized in
accordance with the "General Statement of Policy and Procedures for NRC
Enforcement Actions" (Enforcement Policy), NUREG-1600, at Severity Level III.
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $55,000 is considered for a Severity Level III violation. Because your
facility has been the subject of escalated enforcement actions within the last
two years', the NRC considered whether credit was warranted for Identification
and Corrective Action irr accordance with the civil penalty assessment process
in Section VI.B.2 of the Enforcement Policy. With regard to the factor of
Identification, the NRC considered the following: (1)
you had prior
opportunities to identify the violation including.an April 1988 LOCA
reanalysis, a March 1989 safety system functional inspection, a June 1989
review based on NRC questions on SI pump runout concerns and SI flow tests in
September and November 1990: and (2)
NRC Information Notice (IN) 96-55, dated
October 22, 1996, alerted licensees to problems with assuring NPSH for similar
system configurations. However, you performed an extensive evaluation to
verify NPSH for the SI pumps after receiving requests for calculations related
to the SI system from NRC inspectors who were preparing for the Design
Inspection. As a result of the new calculation, you identified this subtle
design error. Absent your decision to conduct a reanalysis, the issue may not
have been identified. Therefore, on balance, the NRC determined that credit
should be granted for the factor of Identification.
Your corrective actions included: (1)
modifications to the refueling water
storage tank to increase the tank water level; (2)
development of an emergency
core cooling system hydraulic model for the SI and residual heat removal
systems: and (3)
staff training on appropriate methods to ensure the adequacy
of calculations.
In addition, you intend to modify the suction piping for the
B and C SI system piping and conduct a design verification inspection of the
component cooling water system in 1998.
Based on these facts, the NRC
determined that credit was warranted for the factor of Corrective Action.
Therefore, to encourage prompt identification and comprehensive correction of
violations, I have been authorized, not to propose a civil penalty in this
case. However, significant violations in the future could result in a civil
penalty.
1 A Severity Level III violation was issued on May 16, 1996 for failure to control
safeguards information properly (EA 96-120). A Severity Level III problem with a $55,000 civil
penalty was issued on December 12. 1997 for violations related to a mispositioned EDG output
breaker control switch (EA 97-490).
3
NRC Inspection Report No. 50-261/98-03, dated February 6, 1998, included an
apparent violation for a number of calculation deficiencies identified during
the NRC Design Inspection.
The deficiencies included: (1) failures to include
appropriate design parameters or utilize appropriate design inputs in
calculations: (2)
failure to translate design requirements into other design
documents such as drawings or procedures: and, (3)
failures to perform
adequate design verification. After review of the information provided at the
predecisional enforcement conference, the NRC concludes that the deficiencies
do not appear to.have affected design assumptions to such an extent that
safety-related equipment was inoperable. In addition, although the NRC
believes that the deficiencies indicate weaknesses in your control of design
related calculations, the NRC has determined that the violations do not
constitute a breakdown in your design control program.
Therefore, three
violations, each categorized at Severity Level IV. are cited in the enclosed
Notice for these design deficiencies.
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 requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of
this letter, its enclosures, and any response will be placed in the NRC Public
Document Room (PDR).
Sincerely,
Original signed by
Jon R. Johnson for
Luis A. Reyes
Regional Administrator
Docket No. 50-261
License No. DPR-23
Enclosures: 1. Notice of Violation
2. List of Attendees
3. NRC Slides
4. Licensee Material
cc w/encls: (See next page)
4
cc w/encls:
Dale E. Young
Mel Fry, Acting Director
Director, Site Operations
Division of Radiation Protection
Carolina Power & Light Company
N. C. Department of Environment,
H. B. Robinson Steam Electric Plant
Health and Natural Resources
3581 West Entrance Road
3825 Barrett Drive
Hartsville. SC 29550
Raleigh. NC 27609-7721
J. W. Moyer
William D. Johnson
Plant General Manager
Vice President & Senior Counsel
Carolina Power & Light Company
Carolina Power & Light Company
H. B. Robinson Steam Electric Plant
P. 0. Box 1551
3581 West Entrance Road
Raleigh, NC 27602
Hartsville, SC 29550
Karen E. Long.
D. B. Alexander, Manager
Assistant Attorney General
Performance Evaluation and
State of North Carolina
Regulatory Affairs
0HS7
P. 0. Box 629
Carolina Power & Light Company
Raleigh, NC 27602
412 S. Wilmington Street
Raleigh, NC 27601
Robert P. Gruber
Executive Director
H. K. Chernoff, Supervisor
Public Staff - NCUC
Licensing/Regulatory Programs
P. 0. Box 29520
Carolina Power & Light Company
Raleigh, NC 27626-0520
H. B. Robinson Steam Electric Plant
3581 West Entrance Road
Public Service Commission
Hartsville, SC 29550
State of South Carolina
P. 0. Box 11649
T. M. Wilkerson, Manager
Columbia, SC 29211
Regulatory Affairs
Carolina Power & Light Company
Hartsville Memorial Library
H. B. Robinson Steam Electric Plant
147 W. College Avenue
3581 W. Entrance Road
Hartsville, SC 29550
Hartsville, SC 29550
Max Batavia, Chief
Bureau of Radiological Health
Dept. of Health and Environmental
Control
2600 Bull Street
Columbia, SC 29201
5
Distribution w/encls:
LCallan, EDO
HThompson, DEDR
AThadani, DEDE
LChandler. OGC
JGoldberg, OGC
EJulian, SECY
BKeeling, CA
Enforcement Coordinators
RI, RIII, RIV
JLieberman, OE
OE:EA File (BSummers, OE)(2 letterhead)
WBeecher, OPA
GCaputo, 01
TMartin, AEOD
HBell, OIG
SCollin, NRR
CEvans. RII
KClark, RII
RTrojanowski, RII
MTschiltz, OEDO
ABoland, OE
MShymlock, RH
JShea, NRR
JColey, RII
RAiello, RII
RBaldwin, RH
JLenahan, RII
FWright, RH
DThompson, RII
DJones, RH
PUBLIC
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
2112 West Old Camden Road
Hartsville, SC 29550
- SEE PREVIOUS CONCURRENCE
SEND TO PUBLIC DOCUMENT
RO(M
Yes
OFFICE
RII:DRP
RII:DRS
RII:EICS
R11 ORA.
RI:0RA
Signature
.
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JJaudon*
ABoland*
CEvans
DATE 03/
/98
03/
/98
03/
/98
1e-
98/i
03/
/98
COPY? YES
NO
YES NO
YES
NO
NO
YES NO
OFFICIAL RECORD COPY
DOCUMENT NAME:H\\198PEN.ENF\\9844ROtIRFNA
5
Distribution w/encls:
LCallan, EDO
HThompson, DEDR
AThadani, DEDE
LChandler, OGC
JGoldberg. OGC
EJulian, SECY
BKeeling, CA
Enforcement Coordinators
RI, RIII, RIV
JLieberman, OE
OE:EA File (BSummers, OE)(2 letterhead)
WBeecher, OPA
GCaputo, 01
TMartin, AEOD
HBell, OIG
SCollin, NRR
CEvans, RII
KClark, RH
RT~ojanowski, RH
MT~hiltz, OEDO
ABoland, OE
MShymlock, RII
JShea, NRR
JColey, RII
RAiello, RII
RBaldwin, RII
JLenahan. RII
FWright, RII
DThompson, RH
DJones, RII
PUBLIC
NRC Resident Inspector
U.S. Nuclear Regulatory Commission
2112 West Old Camden Road
Hartsville, SC 29550
SEND
TO PUBLIC DOCtfNT ROG?
Yes
OFFICE
RII:DRP
RII:DRS
RII:RA
RII:0RA
Signature
soP
ho/
NAME
iscon
J~audor
a
CEvans
JJohnson
DATE
03/ _
/98
03/3
/98
198
03/
198
03/
198
COPY? YES
NO
NO
A
N
YES
NO
YESN
OFFICIAL RECORD COPY
DOWNT NAME:H:DOPEN.ENF\\98044ROB.0IR\\FINAL
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