ML14182A247

Forwards Svc Water Sys Operational Performance Insp Rept 50-261/93-12 on 930614-0702 & Notice of Violation

ML14182A247
Person / Time
Site:	Robinson
Issue date:	07/30/1993
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Dietz C CAROLINA POWER & LIGHT CO.
Shared Package
ML14182A248	List: IR 05000261/1993012 ML14182A247
References
NUDOCS 9308060064
Download: ML14182A247 (4)

See also: IR 05000261/1993012

Text

JUL 3 0 90

Docket No. 50-261

License No. DPR-23

Carolina Power and Light Company

ATTN: Mr. C. R. Dietz

Vice President

H. B. Robinson Steam Electric Plant

Unit 2

P. 0. Box 790

Hartsville, SC 29550-0790

Gentlemen:

SUBJECT:

NOTICE OF VIOLATION

(NRC INSPECTION REPORT NO. 50-261/93-12

This refers to the Service Water System Operational Performance Inspection

(SWSOPI) conducted by Mr. Walter G. Rogers and others of this office on June 14

through July 2, 1993. The inspection included a review of activities authorized

for your H. B. Robinson Nuclear Power Station. At the conclusion of the

inspection, the findings were discussed with those members of your staff

identified in the enclosed report.

The enclosed inspection report identifies areas examined during the inspection.

The team assessed the service water system's (SWS) operational performance. In

particular, the team performed detailed reviews of the SWS design, maintenance,

operation, surveillance, and testing. The team also assessed the planned or

completed actions in response to Generic Letter (GL) 89-12, "Service Water

System Problems Affecting Safety Related Equipment," issued on July 18, 1989.

Your SWS program was considered as providing minimal assurance of operability.

This conclusion was primarily based upon your weak implementation of GL 89-12

guidelines as they relate to safety related SWS heat exchanger performance

monitoring. We are especially concerned as to whether your actions to date have

explored all approaches available for performance testing of these heat

exchangers. Please address any additional performance monitoring initiatives

underway or planned in a separate correspondence within 60 days of receipt of

this letter.

Based on the results of this inspection, certain of your activities appeared to

be in violation of NRC requirements as specified in the enclosed Notice of

Violation (Notice). Two of these violations were especially significant. The

first dealt in part with an inadequate, abnormal operating procedure. The

resulting NRC review into the validation and verification process gave us

concern that this was an indicator of abnormal operating procedure quality. The

second dealt with inadequate design controls to assure SWS operability. One of

the non-cited violations dealt with a similar subject of an inadequate interface

between your design engineering organization and the site's technical staff. Of

lesser concern were the violations associated with implementation inadequacies

9308060064 930730

PDR ADOCK 05000261

gP.DR,

Carolina Power & Light Co.

2

JUL 30 I=5

in your instrument calibration program, establishing non-conservative vibration

acceptance criteria for pumps, and patching of safety-related pressure

boundaries without using the design change process. The use of Belzona as a

safety-related pressure boundary repair material on repairs of even less than

one square inch, appeared to conflict with the ASME code repair requirements.

Therefore, include in your response your intentions on the use of Belzona as it

relates to the repair of safety-related pressure boundaries.

In addition, the enclosed Inspection Report identified activities that violated

NRC requirements that will not be subject to enforcement action because your

efforts in identifying and/or correcting the violation met the criteria

specified in Section VII.B of the Enforcement Policy.

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 implement 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. With respect to the violation associated with the establishment

of vibration acceptance criteria for pumps, we noted that this violation had

been corrected and those actions were reviewed during this inspection.

Therefore, no response with respect to this matter is required.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this

letter and its enclosures 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, Pub. L. No.96-511.

Should you have any questions concerning this letter, please contact us.

Sincerely,

(Original signed by A. F. Gibson)

Albert F. Gibson, Director

Division of Reactor Safety

Enclosures:

1. Notice of Violation

2. Inspection Report No. 50-261/93-12

3. Appendix A - Acronyms and Abbreviations

4. Appendix B - Generic Letter 89-12 Action Items

cc w/encls:

(See page 3)

Carolina Power & Light Co.

3

JUL 30 993

cc w/encl:

W. Flannagan

Acting Plant General Manager

H. B. Robinson Steam Electric Plant

P. 0. Box 790

Hartsville, SC 29550

Mr. W. S. Orser

Executive Vice President

Nuclear Generation

Carolina Power & Light Company

P. 0. Box 1551 Mail Code - CPB 12

Raleigh, NC 27602

Mr. H. W. Habermeyer, Jr.

Vice President

Nuclear Services Department

Carolina Power & Light Company

P. 0. Box 1551 - Mail 0HS7

Raleigh, NC 27602

Heyward G. Shealy, 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 Environment,

Health & Natural Resources

P. 0. Box 27687

Raleigh, NC

27611-7687

McCuen Morrell, Chairman

Darlington County Board of Supervisor

County Courthouse

Darlington, SC 29535

H. Ray Starling

Vice President - Legal Department

Carolina Power and Light Co.

P. 0. Box 1551

Raleigh, NC 27602

cc w/encls cont'd:

(See page 4)

Carolina Power & Light Co.

4

JUL 30 9Q3

cc w/encls cont'd:

H. A. Cole

Special Deputy Attorney General

State of North Carolina

P. 0. Box 629

Raleigh, NC 27602

Robert Gruber

Executive Director

Public Staff - NCUC

P. 0. Box 29520

Raleigh, NC 27626-0520

J. L. Harrison, Manager

Regulatory Compliance

H. B. Robinson Steam Electric Plant

P. 0. Box 790

Hartsville, SC 29550

Ms. Gayle B. Nichols

Staff Counsel

SC Public Service Commission

P. 0. Box 11649

Columbia, SC 29211

bcc w/encls:

B. Mozafari, NRR

H. Christensen, DRP

J. Jaudon, DRS

G. Hallstrom, DRS

Document Control Desk

NRC Resident Inspector

U. S. Nuclear Regulatory Commission

Route 5, Box 413

Hartsville, SC 29550

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