ML14182A265
| ML14182A265 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/17/1994 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hinnant C CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 9404110068 | |
| Download: ML14182A265 (23) | |
Text
MAR I7 1994 Docket No.: 50-261 License No.:
DPR-23 Carolina Power and Light Company ATTN: Mr. C. S. Hinnant Vice President H. B. Robinson Steam Electric Plant Unit 2 P. 0. Box 790 Hartsville, SC 29550-0790 Gentlemen:
SUBJECT:
ENFORCEMENT CONFERENCE MEETING
SUMMARY
- ROBINSON UNIT 2 This refers to the enforcement conference conducted in the Region II Office on March 14, 1994. The purpose of the meeting was to discuss the status of apparent violations identified during the Augmented Inspection Team investiga tion from November 20 - December 6, 1993, following problems which occurred at Robinson Unit 2 during startup from refueling outage 15. A list of attendees and a copy of your slides are enclosed.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclo sures will be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, please contact us.
Sincerely, Jon R. Johns n, Acting Director Division of Reactor Projects Endlosures:
- 1. List of Attendees
- 2. Licensee Slides cc w/encls:
M. P. Pearson Plant Manager H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 (cc w/encls cont'd - See page 2) 9404110068 940317 PDR ADOCK 05000261 Q
PDR 080 6
Carolina Power and Light Company 2
MAR (cc w/encls cont'd)
H. W. Habermeyer, Jr.
Vice President Nuclear Services Department Carolina Power & Light Company P. 0. Box 1551
- Mail OHS7 Raleigh, NC 27602 R. Krich, Manager Regulatory Compliance H. B. Robinson Steam Electric Plant P. 0. Box 790 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 Environment, Commerce & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 H. Ray Starling Manager - Legal Department Carolina Power and 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 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 bcc w/encls:
(See page 3)
Carolina Power and Light Company 3
bcc w/encls:
H. Christensen, RH B. Mozafari, NRR Document Control Desk NRC Resident Inspector U. S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 RII:DRP RII:DRP RII:DRP RII-DRP JStarefo :tj HChristensen DVerrelli JJ on 03/)Lo/94 03
/94 03/
/94 0 - /94
ENCLOSURE 2 Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit 2 NRC Enforcement Conference March 14, 1994 S.....
Atlanta, Georgia Carolina Power & Light Cornpany
Introduction
- Events reviewed previously with NRC
- Today's focus
- Apparent violations
- Lessons learned
- Corrective actions
- Events were preventable Carnhna Pow & Light Company Page I
Agenda Introduction C. S. Hinnant Procedure Issues/Exceeding 3% Per Hour Power Increase M. P. Pearson Oversight of Purchased Fuel and Fuel Services S. R. Zimmerman Safety Significance C. S. Hinnant Summary C. S. Hinnant Ca4InWIM 1
t Co Page 2 Carohina Power & Light Company
Procedure Issues/Exceeding 3% Per Hour Power Increase
Background
" Fundamental conservative operating practices were not followed
- Operators' focus was too narrow; did not compare available diverse indications
- Operators' mindset was to get through plant startup
" Excessive rate of power increase was a consequence of miscalibrated nuclear instrumentation
- Excessive rate of power increase was not intentional nor detected by Operators C
mpy Page 3 Camhina Power & Light Company P g
Procedure Issues/Exceeding 3% Per Hour Power Increase Safety Significance
- The potential to place the plant in a safety significant condition existed but there were no actual adverse safety consequences
- The actual rate of power increase was analyzed and did not exceed any fuel safety limits
- Management fully understands that inadequate procedures/procedure non-adherence represent a safety concern A r MMPage 4
Camina Powr & Light Company
Procedure Issue/Exceeding 3% Per Hour Power Increase Causes/Corrective Actions
- Cause: Management's failure to properly communicate expectations regarding procedure content and adherence
- Corrective Action: Extensive management intervention actions were initiated to ensure that expectations are understood and met
- Cause: Management's failure to properly monitor/self-assess Operator performance
- Corrective Actions:
- Plant startup training was improved
- A structured self-assessment process specifically covering plant startup activities was implemented Cr L
CaIN P,
MEN;
$mpan y
Page 5 Carolina Power & Light Company
Procedure Issues/Exceeding 3% Per Hour Power Increase Causes/Corrective Actions (Continued)
- Cause: Existing culture
- Corrective Actions: Implementing Near Term Improvement Plan Staffing assessment Effective Performance Management Employee communications Effectively identify and correct problems Self-assessment Expectation s/Standards COia P OCman y
Page 6 Carolina Power & Light Company
Procedure Issue/Exceeding 3% Per Hour Power Increase Causes/Corrective Actions (Continued)
- Cause: Procedure level of detail was not commensurate with task
- Corrective Action: Procedures were upgraded iAgAr IS:
Cmany Page 7 Carolmna Power & Light Company
Agenda Introduction C. S. Hinnant Procedure Issues/Exceeding 3% Per Hour Power Increase M. P. Pearson SOversight of Purchased Fuel and Fuel Services S. R. Zimmerman Safety Significance C. S. Hinnant Summary C. S. Hinnant r
In om an Page 8 Camhna Powrr & Light Company
Inadequate Oversight of Fuel Vendor Design and Manufacturing Activities
Background
m Discussion covers the first two of four examples in apparent violation 3:
- Gadolinia rods mis-loaded by fuel vendor (Siemens)
- Design calculation output data errors
- Errors discovered during planned reactor startup testing program at the 30% power testing plateau C arl n
P a g e 9 Carofina Power & Light Company
Inadequate Oversight of Fuel Vendor Design and Manufacturing Activities Safety Significance
- Operation with affected bundles did not pose any threat to fuel safety limits
- Fuel bundle performance and overall core operations were bounded by UFSAR Chapter 15 Bundle Misloading Event Safety Analysis CI Pwer & Light Coman VI MWPage 10 Carlina Power & Light Company
Inadequate Oversight of Fuel Vendor Design and Manufacturing Activities Causes/Corrective Actions Cause: CP&L review of vendor's design and manufacturing processes was inadequate
- Corrective Actions:
- All CP&L Self-Assessment Teams' recommendations were incorporated into a comprehensive Corrective Action List
- Short term corrective actions were previously reviewed with NRC to support recent plant restart
- Corrective Action List was validated by comparing to NRC findings in AIT Inspection Report
- Programmatic corrective actions were institutionalized
- Awareness of our responsibility for monitoring and control of non-NSSS fuel vendor has been heightened Caroina Por & Light Company
Inadequate Oversight of Fuel Vendor Design and Manufacturing Activities Causes/Corrective Actions (Continued)
- Cause: Fuel vendor's design and manufacturing processes allowed design and bundle fabrication errors; vendor's QA/QC program failed to detect errors
- Corrective Actions:
- CP&L required that fuel vendor respond with corrective actions to all fuel vendor identified items in both the CP&L Self-Assessment Reports and fuel vendor's investigation findings
- CP&L established a tracking system to confirm adequacy of CP&L and fuel vendor identified corrective actions
- Fuel vendor demonstrated effectiveness of immediate corrective actions during fabrication of Harris Plant reload CmlP Light OMpany Page 12 Carohna Power & Light Company
Inadequate Oversight of Fuel Vendor On-Site Fuel Inspection Activities
Background
Discussion covers the last two of four examples in apparent violation 3:
- Failure to control vendor on-site activities which led to introduction of foreign material into fuel bundle guide tube
- Failure to review and approve fuel vendor supplied fuel inspection and handling procedures assaRMI MAn aPage 13 Carolina Power & Light Company
Inadequate Oversight of Fuel Vendor On-Site Fuel Inspection Activities Safety Significance Vendor and independent CP&L analyses confirm no actual or potential adverse safety consequences from loose parts in guide tube C
L Carolina Power &Ligh~t CompanyPa e 4
Inadequate Oversight of Fuel Vendor On-Site Fuel Inspection Activities Causes/Corrective Actions
- Cause: Management failed to adequately define and communicate roles and responsibilities to involved work groups for on-site vendor activities
- Corrective Actions:
- Short term corrective actions to control on-site fuel vendor activities were completed to support recent plant restart
- Management established Interface Agreements to control fuel vendor on-site activities
- Plant line management controls fuel vendor's on-site activities
- Off-site Nuclear Fuels Section provides monitoring in support of plant line management
- CP&L established a tracking system to confirm adequacy of CP&L and fuel vendor identified corrective actions
- Programmatic corrective actions to prevent recurrence were institutionalized Calina Power & Light Company Page 15
Inadequate Oversight of Fuel Vendor On-Site Fuel Inspection Activities Additional Actions:
- Applied lessons learned to all CP&L nuclear units a Shared lessons learned with industry Page 16 Carodna Power & Light Company
Agenda Introduction C. S. Hinnant Procedure Issues/Exceeding 3% Per Hour Power Increase M. P. Pearson Oversight of Purchased Fuel and Fuel Services S. R. Zimmerman Safety Significance C. S. Hinnant Summary C. S. Hinnant Caolina Powe & Light Company Page 17
Safety Significance
- Events were serious
- Plant design and operational data were reviewed and confirmed that there were no actual or potential adverse safety consequences
- Overpower Trip setpoint was conservatively set at 45%
m Fuel Safety Limits were not exceeded m Fuel mis-fabrication was detected at earliest planned core flux map roer Page 18 Cawlhna Pow & Light Company
Summary
- Events were self-identified
- Management has a clear understanding of causes
- Extensive corrective actions have been and continue to be taken
- Events did not result in actual or potential adverse safety consequences
- Assessment of performance is being conducted by external groups while self-assessment capability is being strengthened Page 19 Camlina Power & Light Company