ML18033B747

Responds to Violations Noted in Insp Rept 50-261/89-08. Corrective Actions:Surveillance Procedures Used for safety- Related Steam Driven Auxiliary Feedwater Pump Being Revised to Ensure Compatability When Performed Concurrently

ML18033B747
Person / Time
Site:	Robinson
Issue date:	06/16/1989
From:	Dietz C CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RNPD-89-1910, NUDOCS 8906230153
Download: ML18033B747 (5)

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:.8906230153 DOC.DATE: 89/06/16 NOTARIZED: NO DOCKET ¹ FACIL:50-261 H.B. Robinson Plant, Unit 2, Carolina Power & Light C 05000261 AUTH. NAME AUTHOR AFFILIATION IETZ,C.R. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document, Control Branch (Document Control Desk)

SUBJECT:

Responds to violations noted in Insp Rept 50-261/89-08.

Corrective actions:surveillance procedures being revised.

DISTRIBUTION CODE: ZEOZD COPIES RECEIVED:LTR TITLE: General (50 Dkt)-Insp Rept/Notice of f ENCL Violation J SIZE:

Response

NOTES:

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0 Carolina Power 8 Light Company ROBINSON NUCLEAR PROJECT DEPARTMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 AJAR. 1 6 1889 Robinson File No: 13510H Serial: RNPD/89-1910 United States Nuclear Regulatory Commission Attn.'ocument Control Desk Washington, D. C. 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 NRC INSPECTION REPORT NO. 50-261/89-08 Gentlemen:

Carolina Power and Light Company (CP&L) provides this reply to the Notice of Violation initiated by Inspection Report No. 50-261/89-08.

Severit Level IV Violation (RII-89-08-01-SL4)

Technical Specification 6.5.1.l.l.c requires written procedures be implemented for surveillance and test activities of safety-related equipment. Written procedure OST-202, Steam Driven Auxiliary Feedwater System Component Test, provides instructions for testing the safety-related steam driven auxiliary feedwater (SDAFW) pump. Step 7.2.30.3 of OST-202 requires SDAFW pump steam supply isolation valve MS-Vl-8C to be closed.

Contrary to the above, step 7.2.30.3 was not properly implemented, in that, main steamline isolation valve MS-Vl-3A was closed instead of MS-V1-8C, resulting in a reactor scram.

REPLY (1) Admission or Denial of the Violation CP6L acknowledges the violation.

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Letter to U. S. Nuclear Regulatory Commission Serial: RNPD/89-1910 Page 2 (2) Reason for the Violation

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The root cause of this event is attributed to procedure inconsistencies, which diverted the Operator's attention from the RTGB to the extent that he mistakenly manipulated the incorrect switch to secure the SDAFW pump. The procedures used to perform the surveillance tests contained discrepancies regarding the length of time the SDAFW pump could run on minimum flow recirculation. While OST-202 stated that, under this condition, the pump run time shall not exceed thirty (30) minutes, EST-013 stated that the pump should be run for at least, thirty (30) minutes. This placed additional pressure on the Operator to ensure the SDAFW pump run time was not in violation of either procedure. A contributing factor was that the switch on the Reactor Turbine Generator Board (RTGB) utilized to shut the SDAFW valve MS-Vl-8C is located adjacent to the switch for the Main Steam Isolation Valve V1-3A, and although separated by a space of 2 inches or more, is similar in appearance, and labeling. A review of reactor trip history revealed that a similar event has not occurred for over 15 years. However, the fact. that the Operator performing the tests was newly licensed was identified and considered as a potential causal factor from an experience standpoint.

(3) The Corrective Ste s Which Have Been Taken and The Results Achieved The two surveillance procedures used for SDAFW pump testing are being revised to ensure compatibility when they are performed concurrently. In addition, as a precautionary measure and after discussion with the valve vendor, the MSIV internals will be inspected during a futurh outage. The human factors aspects associated with the proximity of the affected switches on the RTGB have been reviewed as part of the Corrective Action Program process. The results of this review demonstrate that, although identified as a contributing factor to the event, there are enough differences in the switch labeling and location on the RTGB to prevent inadvertent operation. Therefore, the coordination of the two surveillance tests will eliminate the primary contributor to this event, and no immediate changes to the RTGB are necessary.

The Corrective Ste s Which Will Be Taken to Avoid Further Violations A revision to the SDAFW Pump testing procedures will be sufficient to preclude further violations. These changes will be completed by July 31, 1989. In addition, as a result of a Control Room Design Review Audit conducted by the NRC during June 1989, a re-evaluation of RTGB demarkation will be conducted, and actions will be taken as necessary.

The Date When Full Com liance Will Be Achieved Full compliance will be achieved with the procedure revisions discussed above.

Letter to U. S. Nuclear Regulatory Commission Serial: RNPD/89-1910 Page 3 Should you have any questions concerning this submittal, please contact Mr. J. M. Curley, telephone (803) 383-1367.

Very truly yours, C. R. Dietz Manager Robinson Nuclear Project Department RDC:bah cc: Mr. S. D. Ebneter Mr. L. M. Garner INPO